On July 22, 2021, Representative Brad Sherman introduced H.R. 4616, the “Adjustable Interest Rate (LIBOR) Act of 2021” (the “Bill”) into the U.S. House of Representatives. The Act is before the House’s Committee on Financial Services, Committee on Ways and Means, and Committee on Education and Labor. On July 29, 2021, the House’s Committee on Financial Services voted to advance the Bill, along with certain technical amendments proposed by Representative Sherman. The version of the Bill approved by the Committee on Financial Services can be accessed here: Adjustable Interest Rate (LIBOR) Act of 2021 (Committee on Financial Services Version). The Committee on Ways and Means, and Committee on Education and Labor have yet to act on the Bill.
Continue Reading Federal LIBOR “Tough Legacy” Fix Gains Traction
LIBOR Roadmap
Mid-Year Check In on LIBOR Transition Developments
By Donald A. Ensing, Barlow T. Mann & LIBOR Transition Team on
Posted in LIBOR Final Countdown, LIBOR Roadmap
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 Committee (ARRC), the Secured Overnight Financing Rate (SOFR), gained momentum in the business loan market in the first part of 2021, and the ARRC and some regulators responded with efforts to highlight why SOFR should be the benchmark of choice. Set forth below are some of the milestones from an already eventful year, as well as some open questions to be worked through in the second half of 2021.
Continue Reading Mid-Year Check In on LIBOR Transition Developments
Are you Ready for the End of LIBOR? The Fed Issues Guidance on Assessing LIBOR Transition Progress
By Donald A. Ensing & LIBOR Transition Team on
Posted in LIBOR Final Countdown, LIBOR Roadmap
On March 9, 2021, the Federal Reserve in its Supervision and Regulation Letter (the Letter) provided guidance to Federal Reserve examiners and supervised institutions to assist in assessing progress in preparing for the LIBOR transition.
Specifically, examiners are directed to review the supervised institutions’ “planning for, and progress in, moving away from LIBOR.” Supervised institutions should note that examiners are encouraged to consider taking supervisory action if an institution is not ready to cease issuances of new LIBOR-based contracts by the end of 2021.Continue Reading Are you Ready for the End of LIBOR? The Fed Issues Guidance on Assessing LIBOR Transition Progress
OCC Publishes LIBOR-Transition “Self-Assessment Tool”
By LIBOR Transition Team on
Posted in LIBOR Final Countdown, LIBOR Roadmap
The U.S. Office of the Comptroller of the Currency published a three-page self-assessment tool for national banks, federal savings associations, and federal branches and agencies of foreign banking organizations to evaluate their preparedness for the expected cessation of LIBOR. The three-page “tool” poses a series of questions for each bank to answer in a self-assessment. …
Roadmap to the End of LIBOR – Where Are You?
By LIBOR Transition Team on
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?