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

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 work now!
Continue Reading It’s Time to Originate a SOFR Loan! Really!

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 long-time readers have come to expect).  So here’s your first Quick Note.  What will the Alternative Reference Rates Committee (“ARRC”) recommend for the spread adjustment?
Continue Reading Quick Note: What Will the ARRC Recommend for the Spread Adjustment?