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Regulators Finalize Amendments to the Swap Margin Rule and Seek to Extend Implementation Deadline

On June 25, 2020, the Federal Reserve, Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Office of the Comptroller of the Currency (the “Agencies”) finalized amendments to...more

SEC Identifies LIBOR Preparedness as an Examination Priority

On June 18, 2020, the Securities Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused on LIBOR preparedness. OCIE has...more

New ARRC Recommendations for Loans and Spread Adjustments in Light of LIBOR Transition

On June 30, 2020, the Alternative Reference Rates Committee (ARRC) released a series of updates concerning fallbacks and conventions for new variable rate private student loans and syndicated loans, as well as the results of...more

ARRC Announces Best Practices for Completing Transition from LIBOR

On May 27, 2020, the Alternative Reference Rates Committee (ARRC) published best practices for completing the financial industry’s transition away from U.S. dollar (USD) LIBOR. With 19 months remaining before the anticipated...more

ISDA Issues Consultation on Pre-Cessation Fallback Provisions to Facilitate LIBOR Transitioning

On February 25, 2020, the International Swaps and Derivatives Association (ISDA) launched a new consultation on how to implement pre-cessation fallback language into derivatives agreements. Responses are due by no later than...more

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

LIBOR Transition: Fannie Mae and Freddie Mac to Stop Accepting LIBOR, Begin Accepting SOFR

The Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac) announced on Wednesday, February 5th, that they will stop accepting LIBOR-indexed adjustable-rate mortgages...more

EU Clearing Obligation for Interest Rate Swaps Looms

Implementation of the obligation for central clearing of OTC derivatives under the European Market Infrastructure Regulation now seems imminent. The European Commission has adopted a Delegated Regulation that would impose a...more

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