April 2020

I’ve been offline for a bit.  An amalgam of writer’s block caused by the enormity of the Coronavirus mess – what can be said that’s useful – and the consequence of being wildly busy as everyone across financial markets tries to pivot to the new reality.  Unburdened by any knowledge of science, medicine or epidemiology, I have been marinating in the output of such intellectually distinguished journals as The Sun, The Daily Beast, The Onion, The Mirror, The New York Post and Drudge on the daily ups and downs of our plague, its cost in blood and treasure and the disruption it has caused across all aspects of our life.  Consequently, I have opinions but I’ve concluded they’re pretty damn worthless.  We’re in uncharted waters, akin to those bits on a medieval map where the cartographers had no clue and wrote: “Here be Dragons.”
Continue Reading Playing with Broken Toys in Coronavirus Land

As part of Dechert’s COVID-19 Coronavirus Business Impact Broadcast Series, the Crunched Credit team has released its first-ever podcast: Beds Without Heads: Hotels in the Era of the Coronavirus. In this episode, Dechert global finance lawyers Krystyna Blakeslee, Jessica Bula and Haleh Rabizadeh expand on their recent Crunched Credit blog and discuss the impact…

The LIBOR transition plods onward.  Last Wednesday, the Alternative Reference Rates Committee (ARRC) announced its recommended spread adjustment methodology for cash products referencing LIBOR.  Regulators around the world have been clear: interim LIBOR replacement deadlines might slip, but LIBOR’s days are still numbered.  At the end of March, which feels like ten thousand years ago, the Financial Conduct Authority said that “[t]he central assumption that firms cannot rely on LIBOR being published after the end of 2021 has not changed and end-2021 should remain the target date for all firms to meet.”  Amid the constant upheaval as a result of the coronavirus pandemic, isn’t it nice to know that some things aren’t changing?
Continue Reading ARRC Recommended Spread Adjustment Announced

Here is something helpful that has surfaced amidst the fallout, pain and confusion of the global COVID-19 crisis.  The implementation date for the all-too-simple in theory but not-simple-at-all in practice CECL accounting standard has been pushed back by the passage of the CARES Act for banks until the COVID-19 national emergency declared by the president ends or December 31, 2020, whichever is earlier.  In addition, an interim final rule released by the FRB, OCC and FDIC on Friday, March 27th, now provides an option to delay the effects of CECL on regulatory capital for two years (in addition to the original three-year transition period for banks required to adopt CECL during their 2020 fiscal year).  Banks opting to use both forms of relief would be subject to a modified transition period which would be reduced by the amount of quarters CECL was delayed due to the CARES Act.  No relief was provided for non-banks who are otherwise required to follow CECL.
Continue Reading CECL: The Ugly Pig Running Out of Lipstick