Regulators have been increasing their scrutiny of LIBOR transition efforts as they ramp up messaging stressing that the time to act is now. The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a National Exam Program Risk Alert to introduce a LIBOR Examination Initiative on the upcoming discontinuation of, and transition … Continue Reading
This week on the LIBORcast, Dechert’s series on all things related to the LIBOR transition, our very own Sarah Smith and Karen Stretch interviewed Helen Boyd and Nick Miller from the U.K.’s Financial Conduct Authority (the “FCA”).… Continue Reading
While it seems like the COVID pandemic has taken over every waking moment of our lives, the impending end of LIBOR marches ever onward. All signs point to a termination date for the troubled benchmarks at the end of 2021, pandemic be damned. The purpose of this post is not to discuss the road to transition … Continue Reading
COVID-19 has driven anxiety over the LIBOR transition right off almost everyone’s top-of-mind list and yet the crisis is taking no notice of that lack of regard and soldiering on. The ARRC continues to beaver away, generating guidance and advice and otherwise proselytizing the need to get on with it and be ready for transition … Continue Reading
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, … Continue Reading
The Federal Reserve Bank of New York announced last week that it will be publishing “Average SOFR” for 30, 90 and 180 days on its website starting on March 2, 2020. The confusing thing about this announcement is that the Fed has named these rates the “SOFR Averages” when the rates clearly use the ISDA … Continue Reading
The ARRC Consultation on Spread Adjustment Methodologies for Fallbacks in Cash Products Referencing USD LIBOR is finally here. How the spread adjustment from LIBOR to a SOFR index will be calculated is one of the more consequential open items on the ARRC’s to-do list.… Continue Reading
It is time to start originating Single Asset Single Borrower (SASB) large loans priced on SOFR. There, I said it. Not just LIBOR indexed loans containing a SOFR fall back when LIBOR inevitably goes away, but new loans indexed to Compounded SOFR, implementing all the necessary tweaks to documents, systems and processes to make that … Continue Reading
One of the good things about the 24/7 news cycle, perhaps one of its few positive externalities, is that it’s a boon for the pontification business. It enables all sorts of otherwise serious people to make fools of themselves day in and day out predicting generally gloomy stuff, as sunshine doesn’t sell. As a card-carrying … Continue Reading
As is our tradition here at Crunched Credit, each year, about this time, we award our Golden Turkey Awards. Once again, I must say that we are utterly blessed with so many worthy candidates. The truly deserving have once again wrangled with vision and astounding persistence to earn a spot on our acclaimed list. To … Continue Reading
Last week, the U.S. Department of the Treasury released proposed rules providing tax guidance around various LIBOR replacement issues. Long anticipated. The defenestration of LIBOR will leave considerable broken glass in its wake. Perhaps just so the tax professionals wouldn’t feel left out, the end of LIBOR will create a series of tax problems. Very … Continue Reading
The LIBOR transition process is an affair of headache-inducing complexity. Amidst the thousands of gallons of ink spilled on the subject, we thought it might be useful, from time to time, to give you some important information in bite-sized servings (don’t worry, we will continue to publish lengthy, irreverent commentaries on the subject that our … Continue Reading
The US economy is about to pay the butcher’s bill for a massive disruption of worldwide financial markets resulting from the elimination of the London Interbank Offered Rate, or LIBOR. And, we are doing this on purpose. It seems the denizens of the heights of our international financial fabric felt they had to do this … Continue Reading
We are all going to be heartedly sick of discussing LIBOR and LIBOR transition long before it becomes a thing at the end of 2021, but we really need to get this done. I can’t make this at all funny. We have a problem…but not a solution. Fixing it is going to be a heavy … Continue Reading
LIBOR is going away, but that’s sort of old news at this point. However, it has been received wisdom that only after the Bank of England stops imposing an obligation upon member banks to publish LIBOR quotes as at the beginning of 2021, would LIBOR go away and then we would need a replacement. … Continue Reading
Geeking out, I just finished reading the second report from the Alternate Reference Rates Committee that was just published jointly by the Financial Stability Board (FSB) and the Financial Stability Oversight Council (FSOC) in cooperation with the Alternate Reference Rates Committee (ARRC). Does that scream bureaucracy in full, or what? The report runs 40 pages, awkwardly … Continue Reading
You know, sometimes life’s problems smack you against the side of the head like a 2×4, and sometimes it’s just a multiplicity of middling offenses that become so annoying that you might just want to roll over and die. Think anything involving a conversation with the DMV or the phone company. Today, we’re talking the … Continue Reading
What if LIBOR is disrupted? Something new to worry about, as if Europe’s slow motion financial train wreck, the U.S. elections, the fiscal cliff, the slowing U.S. economy, Mid-east tensions and uncertainty about the Asian economy aren’t enough. We now have a broken LIBOR to entertain us too!… Continue Reading
