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Secured Overnight Funding Rate (SOFR) Interest Rates Financial Conduct Authority (FCA)

Jones Day

FCA Consulting on Proposed Changes to the Derivatives Trading Obligation

Jones Day on

The Background: In 2021, the Financial Conduct Authority ("FCA") and HM Treasury began consulting on the Wholesale Markets Review (the "Review"), a broad review of the structure, functioning, and regulation of secondary...more

A&O Shearman

USD LIBOR panel has ceased…what now?

A&O Shearman on

June 30th has passed and one-, three- and six-month USD LIBOR settings have ceased to be published. As confirmed by the FCA on 3 April 2023, the ICE Benchmark Administration (IBA) has begun publishing non-representative...more

Cadwalader, Wickersham & Taft LLP

FCA Announces That USD LIBOR Is Not Representative

The last publication of USD LIBOR on the basis of panel bank submissions occurred on June 30, 2023. As of July 3, 2023, 1-, 3- and 6-month USD LIBOR settings will be calculated using a synthetic methodology based on CME Term...more

ArentFox Schiff

A Long Hot Summer: Effective Variable Rates Subject to Increase (Irrespective of General Market Conditions)

ArentFox Schiff on

There are major issues arising from the phaseout of the US Dollar London InterBank Offered Rate (LIBOR), which will soon become apparent in connection with LIBOR’s fast-approaching end date. This will dramatically impact many...more

Cadwalader, Wickersham & Taft LLP

FCA Compels the Publication of ‘Synthetic’ USD LIBOR

After USD LIBOR stops being published on June 30, 2023, “synthetic” USD LIBOR will continue to be published for a limited period, according to the UK’s Financial Conduct Authority (“FCA”). The FCA said that the “synthetic”...more

Mayer Brown Free Writings + Perspectives

FCA Synthetic LIBOR Announcement

On April 3, 2023 the U.K. Financial Conduct Authority (“FCA”) announced that it will require the administrator of U.S. dollar LIBOR to continue to publish one, three and six-month U.S. dollar LIBOR settings until September...more

ArentFox Schiff

The End of LIBOR: New Year’s Resolutions

ArentFox Schiff on

Last year, the United Kingdom Financial Conduct Authority (UK FCA) announced the following: - ‘Zombie’ USD LIBOR for proposed use from July 1, 2023, through September 30, 2024, except for cleared derivatives - 1-Month and...more

Ballard Spahr LLP

As SOFR Deadline Looms, FCA Proposes Extensions for 'Synthetic' Approach to Legacy USD LIBOR Contracts

Ballard Spahr LLP on

Summary - The United Kingdom Financial Conduct Authority (FCA) on November 23 published its Consultation on ‘Synthetic’ U.S. Dollar LIBOR to advance some synthetic applications of USD LIBOR from June 30, 2023, until...more

Cadwalader, Wickersham & Taft LLP

FCA Seeks Feedback on ‘Synthetic’ USD LIBOR

On November 23, the UK’s Financial Conduct Authority (“FCA”) released its further consultation to require the administrator of LIBOR to publish a synthetic version of 1-, 3-, and 6-month U.S. dollar LIBOR settings for a...more

Cadwalader, Wickersham & Taft LLP

FCA Issues Statement on the End of Synthetic Sterling LIBOR

On September 29, the UK’s Financial Conduct Authority (“FCA”) issued a statement that the publication of the 1-month and 6-month synthetic sterling LIBOR would permanently cease at the end of March 2023....more

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR

On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to taxpayers with respect to the widely reported...more

Bass, Berry & Sims PLC

Katie Smalley Outlines Transition from LIBOR to SOFR

Bass, Berry & Sims PLC on

The moment has come – the moment that all have been awaiting since the summer of 2017 when the UK Financial Conduct Authority made its announcement to ultimately cease compelling reporting of the ubiquitous floating interest...more

Holland & Knight LLP

CFPB Issues Final Libor Transition Rules

Holland & Knight LLP on

The Consumer Financial Protection Bureau (the Bureau) has issued final regulations (Final Regulations) to facilitate the transition away from Libor (the London Interbank Offered Rate) in the consumer credit market and to...more

ArentFox Schiff

Federal Law to the Rescue?

ArentFox Schiff on

Snidely Whiplash kidnaps Nell and, in the show’s opening, ties her to the railroad tracks to get even with his nemesis, Dudley Do-Right, of the famed Royal Canadian Mounted Police. Menacing music plays. In each episode,...more

Dechert LLP

LIBOR and SOFR:  Welcome to a Two-Speed Market?

Dechert LLP on

The Great Index Reformation is coming.  (I note in passing that the last Reformation led to the 100 Years War…just saying.)  This is a massive change to our market that did not bubble up from the great unwashed on the...more

Dechert LLP

Term SOFR is Here - The ARRC Recommends CME Group’s Term SOFR Rates for Use

Dechert LLP on

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

Sheppard Mullin Richter & Hampton LLP

Latest Milestone in LIBOR Replacement Passed

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

Dechert LLP

It’s Time for The Industry to Engage on SOFR’s Voldemort Problem

Dechert LLP on

It’s a rule around here that I don’t write on the same topic twice in a row because if you don’t get bored, I will.  I am making an exception this week to revisit last week’s blog about the industry’s failure to take on, or...more

Dechert LLP

The Powers That Be Are Rallying Around SOFR and That’s a Mistake

Dechert LLP on

To my gentler readers, first an apology for this interregnum in publication.  I’ve been sitting on this commentary like a hen on an egg for weeks.  All I can say is having to work for a living gets in the way of writing about...more

ArentFox Schiff

LIBOR Transition Comparison: UK vs. US (Round II)

ArentFox Schiff on

This article summarizes the significant problems with the LIBOR transition in the US as compared to the UK (and the rest of the world). This summary is based upon the keynote speech at the United Kingdom Financial Conduct...more

McGuireWoods LLP

Mid-Year Check In on LIBOR Transition Developments

McGuireWoods LLP on

The last few months have seen the pace of change accelerate in the business loan market’s transition away from LIBOR. Several alternatives to the replacement benchmark rate recommended by the Alternative Reference Rates...more

Snell & Wilmer

LIBOR: The End is Nigh (Really!)

Snell & Wilmer on

LIBOR—the London Inter-bank Offered Rate—has been a key interest rate benchmark in commercial lending since the 1980s. LIBOR is derived from the interest rates at which major banks would lend to each other on a short-term...more

Katten Muchin Rosenman LLP

Tax Implications of LIBOR Reform

LIBOR (London Interbank Offered Rate) is a set of interest rate benchmarks based on the rates at which banks are willing to borrow wholesale-unsecured funds. It is used in numerous financial instruments such as loans,...more

Dechert LLP

LIBOR’s Winter is Coming

Dechert LLP on

God knows I’m as sick of LIBOR transition as you are and writing about it twice in quick succession is annoying, but I think necessary. Here’s the headline which I don’t think has gotten the visibility it deserves: ...more

Polsinelli

Recent Developments in the Transition from LIBOR

Polsinelli on

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

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