There's been a flurry of regulatory activity in the UK and Europe over the past few weeks. Here's a look at the highlights. The EU has renewed its determination that the solvency regime for US-headquartered insurers and...more
Back in March of 2021, we covered a number of developments pertaining to the end of LIBOR that came out of certain announcements made early that month by the Intercontinental Exchange Benchmark Administration (the “IBA”),...more
As market participants prepare to submit comments on the recent proposal of the UK’s Financial Conduct Authority (the “FCA”) (available here) to require the temporary publication of a “synthetic” 1-, 3- and 6-month USD LIBOR,...more
This latest edition of the regulatory initiatives paper sets out at a high level the core regulatory issues that are likely to impact private fund managers in the coming months, including an overview of the key actions needed...more
On March 5, 2021, the Financial Conduct Authority (FCA) announced the future cessation or loss of representativeness of the 35 LIBOR benchmark settings currently published by ICE Benchmark Administration (IBA), the authorized...more
In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more
The Internal Revenue Service and the US Treasury Department have issued final regulations providing rules for taxpayers transitioning from interbank offered rates to qualified rates. These regulations provide financial...more
This past Monday, July 26, marked passage of the most recent major milestone in the replacement of LIBOR as the benchmark USD interest rate. Following the recommendation of the CFTC’s Market Risk Advisory Committee (MRAC)...more
While the end of widespread use of the U.S. Dollar London Inter-Bank Offered Rate (“LIBOR”)1 has been looming for several years, there have been a number of key developments recently in the transition away from LIBOR that...more
Ready or not, borrowers are involuntarily seeing changes in the interest rates they are being charged. Why, you ask? Because there are serious, systemic risks associated with the most widely used interest rate basis in the...more
March was a big month for the LIBOR endgame. There were several big announcements, some important (but technical) developments, and new deadlines. Simply put, the March developments matter to the fund finance community...more
On March 25, 2021, the Alternative Reference Rates Committee (the “ARRC”) issued supplemental guidance to its recommended hardwired fallback language for U.S. dollar LIBOR denominated syndicated and bilateral business loans....more
On 5 March 2021, the Financial Conduct Authority ("FCA") announced (the "FCA Announcement") the future cessation or loss of representativeness for all 35 LIBOR settings currently published by ICE Benchmark Administration...more
Recent statements by LIBOR authorities in the UK have implications for benchmark fallbacks in US documents. The UK’s Financial Conduct Authority ("FCA") and ICE Benchmark Administration ("IBA") released statements1 on...more
The Infrastructure Projects Authority (“IPA”) recently published guidance on LIBOR transition and key considerations for both UK PFI/PPP contractors and their financiers in respect of active LIBOR transition. Whilst this...more
On Friday, 5 March 2021, the Financial Conduct Authority (FCA) announced that all 35 LIBOR benchmark settings as currently published by ICE Benchmark Administration (IBA), the administrator of LIBOR, will either cease to be...more
On March 5, 2021, the ICE Benchmark Administration (the “IBA”) issued feedback that it had completed the consultation with LIBOR panel banks that it began in December 2020, and stated that it will be unable to publish certain...more
Recent developments mean a delayed departure for LIBOR. The cessation of most U.S. dollar LIBOR tenors has been delayed until June 30, 2023. Aircraft financiers, borrowers and lessors should take advantage of the...more
This bulletin provides a timely update on two emerging issues related to LIBOR transition – namely, requirements that administrative agents (including private credit lenders acting in that role on their facilities) may be...more
ICE Benchmark Administration Limited ("IBA") upends market expectations by announcing a consultation on an 18-month extension for most tenors of USD LIBOR. IBA announced on November 30, 2020, that it would launch a market...more
The Financial Conduct Authority (“FCA”), the UK regulator of LIBOR, announced several years ago that it would no longer compel panel banks to provide LIBOR quotes after December 31, 2021. The FCA also stated in March of this...more
On November 30, ICE Benchmark Administration ("IBA"), the administrator of LIBOR, announced a consultation on its intention to cease publishing USD LIBOR (1) in the case of 1-week and 2-month LIBOR, on December 31, 2021; and...more
Often referred to as “the world’s most important number”, the London Interbank Offered Rate (LIBOR) is used as the reference interest rate for a range of commercial and financial contracts worth hundreds of trillions of...more
On November 30, 2020, the UK and US banking regulators published a series of statements that provide further guidance and milestones for the transition away from the London Inter-Bank Offered Rate (LIBOR) and cessation of...more
On Monday, November 30, 2020, ICE Benchmark Administration (“IBA”), as administrator of LIBOR, announced that it will consult in early December 2020 on its plan to cease publication of the overnight and one-, three-, six- and...more