March 5, 2021 marks an important day in the LIBOR transition process as the ICE Benchmark Administration (IBA), UK Financial Conduct Authority (FCA) and ISDA made important announcements on the cessation of LIBOR. In recent years the Bank of England and the FCA have made it clear that the lack of an active underlying market makes LIBOR unsustainable and unsuitable for widespread use. As a result, the Bank of England and FCA have worked closely with market participants and other regulatory authorities to ensure alternatives to LIBOR are available and that existing contracts can be transitioned onto these alternatives to safeguard financial stability and market integrity.

With today’s announcements by the IBA, FCA and ISDA, the timeline for the cessation of LIBOR has been fixed.


Continue Reading Mark the Date: Important Announcements by IBA, FCA and ISDA

On February 15, 2021, the UK Treasury published a consultation paper on potential legal ‘safe harbor’ rules for legacy LIBOR-referencing contracts which have been amended by the Financial Conduct Authority (the FCA) under the Financial Services Bill.

Continue Reading UK HM Treasury Consults on Safe Harbor Rules for Legacy LIBOR Contracts

With the end of LIBOR in sight, on January 11, 2021 the Bank of England, FCA and Working Group on Sterling Risk-Free Reference Rates (the Working Group) published a joint statement on the final countdown to the ceasing of publications of all GBP LIBOR settings at the end of 2021 and an updated 2021 Roadmap to assist business in their preparations for the LIBOR transition. Market participant are encouraged to take the Working Group’s updated roadmap into consideration in the transition plans for 2021.

Continue Reading Roadmap to the End of LIBOR – Where Are You?

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 12-month U.S. Dollar LIBOR (“USD LIBOR”) settings immediately following the LIBOR publication on June 30, 2023.[1] This announcement represents an effective extension of the end date for USD LIBOR, which previously was expected to cease following 2021.

Continue Reading ICE Benchmark Administration Proposes Extension of Most U.S. Dollar LIBOR Tenors Through June 2023; Move is Supported by the UK Financial Conduct Authority

On November 18, 2020, the LIBOR administrator ICE Benchmark Administration (IBA) announced that they will consult on their intention to cease publication of GBP, EUR, CHF and JPY LIBOR settings across all tenors. Their announcement also indicated that IBA remain in talks with the FCA, other official sector bodies and panel banks regarding

On October 21, 2020, the UK Government introduced the Financial Services Bill (the Bill) to Parliament. The Bill is seen as a vital step towards ensuring the UK’s continued status as a global finance hub in the post-Brexit world, and it also introduces the UK Government’s legislative fix for LIBOR-referencing contracts that face insurmountable barriers in the transition from LIBOR (“tough legacy contracts”), as announced in June and discussed in our earlier update.

Continue Reading UK Financial Services Bill: Amendments to the Benchmarks Regulation to support LIBOR transition

In a statement made on September 29, 2020, the Financial Conduct Authority (FCA) and Bank of England endorsed a proposal by the Working Group on Sterling Risk-Free Reference Rates (the Working Group) that the interdealer quoting convention should change such that prices be linked to SONIA, rather than LIBOR. This change was originally to be implemented from March 2, 2020, but has been delayed due to the COVID-19 pandemic.

Continue Reading FCA, Bank of England Urge Shift in Swaps Quoting Conventions to Assist in Transition From LIBOR

As the world continues to deal with the COVID-19 pandemic, the end of 2021 deadline for the LIBOR transition has remained unchanged. However, certain deadlines along the way have been extended in recognition of the difficulties that market participants face in these tumultuous times.

In what follows, we explore the current timelines on the path to the transition from LIBOR.


Continue Reading Updated LIBOR Transition Timeline in the COVID-19 Pandemic

Update: The Bank of England has delayed the introduction of increased haircuts to apply to all LIBOR linked collateral. For more details, please refer to our July 28 post.

The FCA and the Bank of England (BoE) have encouraged market participants to switch from LIBOR to SONIA from March 2, 2020 in all new trades.  Some market participants have already started referencing RFRs.  For the year to date ending on March 6, 2020 the following notionals* (as published by ISDA) were traded.

RFR Traded Notional Trade Count
SOFR $222.9 billion 998
SONIA $7.1 trillion 6,304
€STR $0.9 billion 16
SARON $4.2 billion 9
TONAR $76.3 billion 178


Continue Reading Recent Commentary from the UK Financial Conduct Authority (FCA) and Bank of England

In a letter to the International Swaps and Derivatives Association (ISDA) on January 20, 2020, the Financial Conduct Authority (FCA) confirmed the possibility that LIBOR may continue to be published for a short period after regulators have announced that it is no longer representative of an underlying market (a non-representative LIBOR). The European Benchmarks Regulation could prohibit EU-supervised firms from entering into new derivatives transactions referencing such a non-representative LIBOR. As a result, the FCA encouraged ISDA to provide the derivatives market with the ability to insert triggers into their derivatives contracts to allow fallbacks to risk-free rates if such a regulatory announcement is made prior to the cessation of LIBOR (a pre-cessation trigger).

Continue Reading ISDA to Revisit LIBOR Pre-Cessation Triggers