United States

Topic: LIBOR

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The LIBOR Transition – CFTC issues more LIBOR transition relief

On August 31, 2020, in response to requests by the Alternative Reference Rates Committee (ARRC), the US Commodities Futures Trading Commission (CFTC) issued revised no-action letters to swap dealers and other market participants relating to the transition from use of the London Interbank Offered Rate (LIBOR) as a reference rates in transactions. These letters supersede … Continue Reading

The LIBOR Transition – ARRC Releases Helpful Resource Guides for Market Participants

With the potential end of LIBOR quickly approaching in only 16 months, the ARRC has been publishing many helpful resources to aid in the market’s transitions from LIBOR to SOFR, including multiple quick reference resource guides listed below. As part of the ARRC’s Summer Series (a webinar series aimed at educating the public about SOFR … Continue Reading

The LIBOR Transition — US banking regulators caution banks on LIBOR transition risks

As noted in previous LIBOR Transition posts, the availability of LIBOR as a reference rate is not guaranteed beyond the end of 2021. On July 1, 2020, the Federal Financial Institutions Examination Council (FFIEC), which consists of US federal and state banking regulators and the Consumer Financial Protection Bureau, issued a Joint Statement highlighting the … Continue Reading

The LIBOR Transition — CFPB addresses elimination of LIBOR in consumer credit transactions

LIBOR is used as a component of an interest or finance charge in consumer transactions as well as the commercial transactions we have discussed in prior LIBOR Transition posts. On June 4, 2020, the US Consumer Financial Protection Bureau (CFPB), issued a proposed rule that would amend US consumer credit regulations to address the pending … Continue Reading

The LIBOR Transition – ARRC 2020 Best Practices for Completing the Transition from LIBOR

Following on our post discussing the ARRC’s publication of their 2020 Key Objectives, we mentioned that ARRC panned to release a set of recommended best practices. As promised, the ARRC has published guidance for Best Practices for Completing the Transition from LIBOR (“Best Practices Guidance”), along with an accompanying fact sheet, which sets forth recommended … Continue Reading

The LIBOR Transition – ARRC’s further consultation on spread adjustment methodologies and advice on the SOFR Index

Following on our post discussing the ARRC’s recommendations outlining a spread adjusting procedure, we mentioned that the ARRC planned to release a more detailed final recommendation of the spread adjustment methodology for cash products. On May 6, 2020, the ARRC released a supplemental consultation seeking further views on certain technical questions for the spread adjustment … Continue Reading

The LIBOR Transition – ARRC 2020 Key Objectives

Following up on our past posts on the transition away from the London Interbank Offering Rate (“LIBOR”), and other interbank offering rates (“IBOR”) denominated in other currencies, in this post, we discuss the key objectives for 2020 released by the Alternative Reference Rates Committee (“ARRC”), the group of private market participants advising the Federal Reserve … Continue Reading

The LIBOR Transition – ARRC issues recommendations outlining spread adjusting procedure

Following up on our past posts on the transition away from the London Interbank Offering Rate (“LIBOR”), and interbank offering rates (“IBOR”) denominated in other currencies, in this post, we discuss the agreement reached by the members of the Alternative Reference Rates Committee (“ARRC”) on a spread adjustment methodology for cash products referencing U.S. dollar … Continue Reading

The LIBOR Transition – ARRC’s Recommended Fallback Contract Language – New Variable Rate Private Student Loans

Following up on our past posts on the transition away from the London Interbank Offering Rate (“LIBOR”), and other interbank offering rates (“IBOR”) denominated in other currencies, in this post, we discuss the proposal from the Alternative Reference Rates Committee (“ARRC”) consultation on fallback contract language for new variable rate private student loans. This is … Continue Reading

The LIBOR Transition – ARRC releases recommended NY Legislation on LIBOR

Following up on our past posts on the transition away from the London Interbank Offering Rate (“LIBOR”), and other interbank offering rates (“IBOR”) denominated in other currencies, we discuss the proposal from the Alternative Reference Rates Committee (“ARRC”) for New York legislation, which was published on March 6, 2020. The ARRC is a group of … Continue Reading

The LIBOR Transition – SFA Survey on Potential LIBOR Transition Solutions for Securitization Market Legacy Vehicles and Instruments

Following up on our past posts, in this update on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates (“IBOR”) denominated in other currencies, we discuss a Structured Finance Association (“SFA”) survey with respect to potential LIBOR transition solutions in the securitization industry. The SFA is group of structured finance … Continue Reading

The LIBOR Transition –Global and US Regulators Expectations on LIBOR Planning

Following up on our past posts, in this update on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates (“IBOR”) denominated in other currencies, we discuss some recent issuances by global and US government regulators on the LIBOR transition. The LIBOR transition requires considerable work from all market participants and … Continue Reading

The LIBOR Transition – Potential New York State Legislation

Following up on our past posts, this update on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates (“IBOR”) denominated in other currencies, we discuss in this post the Alternative Reference Rates Committee (“ARRC”) and its role in potential New York State legislation with respect to the LIBOR transition. As … Continue Reading

The LIBOR Transition – ISDA Consultation Market Responses

Following up on our past posts, this update on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates (“IBOR”) denominated in other currencies, we discuss in this post the International Swaps and Derivatives Association (“ISDA”) Summary of Responses to the ISDA Consultation on Final Parameters for the Spread and Term … Continue Reading

The LIBOR Transition – ARRC’s LIBOR Fallback Language for Residential Mortgages

Following up on our past posts, this update on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates (“IBOR”) denominated in other currencies, concerns the Alternative Reference Rates Committee (“ARRC”), and the adoption by Freddie Mac and Fannie Mae (which are US government-sponsored enterprises in the housing finance market) of … Continue Reading

The LIBOR Transition – Tax consequences of switching from LIBOR

Following up on our past posts (available here and here) on the transition away from LIBOR (London Interbank Offering Rate), and other interbank offering rates denominated in other currencies (collectively with LIBOR, “IBOR”), we discuss in this post the US Internal Revenue Service’s (“IRS”) proposed “Guidance on the Transition From Interbank Offered Rates to Other … Continue Reading

The LIBOR Transition – the Secured Overnight Financing Rate (SOFR)

Following up on our previous post of earlier this week, in this update on the transition away from LIBOR (London Interbank Offering Rate) as the reference rate of choice for financial transactions, we discuss one such alternative, the Secured Overnight Financing Rate (SOFR) issued by the Federal Reserve Bank of New York (”FRBNY”). On November … Continue Reading

The LIBOR Transition — What is LIBOR and why is it important?

Since its creation by the British Bankers Association in the 1980s, the London Interbank Offering Rate (“LIBOR”) has been used as a reference rate for borrowing costs between banks. The LIBOR calculation today is coordinated by the International Continental Exchange Benchmark Administration, which receives information on a daily basis from a group of global money … Continue Reading
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