An update from the Dechert LIBOR taskforce - On July 29, 2021, the Alternative Reference Rates Committee (the “ARRC”) formally recommended the forward-looking term rates based on the secured overnight financing rate (“SOFR”)...more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations issued a National Exam Program Risk Alert on June 18, 2020 (Risk Alert), which introduces an examination initiative on the upcoming...more
7/31/2020
/ Alternative Reference Rates Committee (ARRC) ,
Broker-Dealer ,
Clearing Agencies ,
Compliance ,
Interest Rates ,
Investment Adviser ,
Investment Companies ,
Libor ,
Municipal Advisers ,
OCIE ,
Risk Alert ,
SEC Examination Priorities ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Traders ,
Transitional Arrangements
The Federal Reserve Bank of New York announced last week that it will be publishing “Average SOFR” for 30, 60 and 90 days on its website starting on March 2, 2020. The confusing thing about this announcement is that the Fed...more
The ARRC Consultation on Spread Adjustment Methodologies for Fallbacks in Cash Products Referencing USD LIBOR is finally here. How the spread adjustment from LIBOR to a SOFR index will be calculated is one of the more...more
It is time to start originating Single Asset Single Borrower (SASB) large loans priced on SOFR. There, I said it. Not just LIBOR indexed loans containing a SOFR fall back when LIBOR inevitably goes away, but new loans indexed...more
Last week, the U.S. Department of the Treasury released proposed rules providing tax guidance around various LIBOR replacement issues. Long anticipated. The defenestration of LIBOR will leave considerable broken glass in its...more
10/21/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
IRS ,
Libor ,
Proposed Regulation ,
Proposed Rules ,
REMIC ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
The LIBOR transition process is an affair of headache-inducing complexity. Amidst the thousands of gallons of ink spilled on the subject, we thought it might be useful, from time to time, to give you some important...more
The staffs of the Securities and Exchange Commission’s Division of Corporation Finance, Division of Investment Management (IM Division), Division of Trading and Markets, and Office of Chief Accountant (collectively, Staff) on...more
9/25/2019
/ Adjustable Rate Financial Products ,
Alternative Reference Rates Committee (ARRC) ,
Banks ,
Benchmarks ,
Broker-Dealer ,
Contract Amendments ,
Contract Terms ,
Derivatives ,
Division of Corporate Finance ,
Division of Investment Management ,
Division of Trading and Markets ,
FASB ,
Federal Reserve ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Regulatory Agencies ,
IASB ,
ICE Benchmark Administration (IBA) ,
Insurance Industry ,
Interest Rates ,
Investment Adviser ,
Investment Companies ,
Libor ,
Market Participants ,
Modification ,
Policies and Procedures ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Transitional Arrangements
LIBOR is going away, but that’s sort of old news at this point. However, it has been received wisdom that only after the Bank of England stops imposing an obligation upon member banks to publish LIBOR quotes as at the...more
Geeking out, I just finished reading the second report from the Alternate Reference Rates Committee that was just published jointly by the Financial Stability Board (FSB) and the Financial Stability Oversight Council (FSOC)...more