Fed Seeks Comment on Default Rules for LIBOR-Linked Contracts

The London Interbank Offered Rate (LIBOR) reference rate will be discontinued after June 30, 2023. Financial institutions are well underway to replace the now defunct reference rate with a more suitable baseline reference rate in credit and trade agreements. The Federal Reserve recently issued a proposal to provide default rules for LIBOR-linked contracts void of terms for an alternative benchmark. See this analysis to understand the LIBOR transition requirements and the Federal Reserve’s recent proposed regulation to implement the Adjustable Interest Rate (LIBOR) Act.

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• TRID Disclosure and Closing Process
  Explore this practice note for key information on amendments to TILA's Regulation Z which  extended effective and compliance dates for the LIBOR transition into 2022 and 2023. The note also contains information on the Alternative Reference Rates Committee (ARRC) views on the Secured Overnight Financing Rate (SOFR) as the preferred index rate replacing LIBOR, and the Consumer Finance Protection Bureau (CFPB) views on alternative replacements, including the prime rate.

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• LIBOR Phase-Out 2023 Risk Factor
  Use this template to supplement your organization’s risk disclosures relating to the phase-out of LIBOR.

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• Bank Regulatory Counsel Resource Kit and In-House Banking and Financial Services Resource Kit are just two of the resources available to cover key issues, laws, and regulations applicable to in-house lawyers and counsel advising on LIBOR transition requirements. Resource kits include helpful practice notes, templates, checklists, and articles.
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