On 19 July 2022, the Federal Reserve Board (the “Board”) published a notice of proposed rulemaking – Regulation Implementing the Adjustable Interest Rate (LIBOR) Act, as it was required to do by Section 110 of the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”), which was signed into law on 15 March 2022.
Financial institutions in Australia, the US and Europe have for years used LIBOR as a common benchmark for various adjustable-rate loan products. This is set to change in 2022 as LIBOR is effectively phased out. Mayer Brown partners Amanda Baker, Stuart Litwin and Jon Van Gorp explore preparedness for the transition.
On December 22, 2021, in response to a request from the Alternative Reference Rate Committee (ARRC) and a further request from the Futures Industry Association (FIA), the United States Commodity Futures Trading Commission (CFTC) issued five technical no-action letters providing additional, and extending existing, time-limited, no-action relief and guidance for certain London Interbank Offered Rate (LIBOR) transition matters.