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Financial Services Law Insights and Observations

FSB releases LIBOR transition roadmap

Federal Issues LIBOR Financial Stability Board

Federal Issues

On October 16, the Financial Stability Board released a “Global Transition Roadmap for LIBOR,” which details the steps financial firms and their clients should take “in order to ensure a smooth LIBOR transition” from now through 2021. In addition to identifying actions that should already be complete, the roadmap details the following steps:

  • ISDA Fallbacks Protocol Effective Date. Firms should adhere to the International Swaps and Derivatives Association’s (ISDA) IBOR Fallback Protocol and IBOR Fallback Supplement, which will be launched on October 23 and take effect on January 25, 2021 (covered by InfoBytes here).
  • By the end of 2020. Lenders should be able to offer non-LIBOR products to customers.
  • By mid-2021. Firms should have identified which contracts can be amended and make contact with other parties to prepare for the use of alternative rates. Firms should execute formalized plans to covert legacy LIBOR contracts to alternative rates. 
  • By the end of 2021. All new business should be conducted in, or capable of switching immediately to, alternative rates.

For continuing InfoBytes coverage on the LIBOR transition see here.