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ARTICLE · 07 SEPTEMBER 2022

Proposed Regulation ZZ's LIBOR Transition Rules For Tough Legacy Contracts

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The London Interbank Offered Rate ("LIBOR") has been the dominant interest rate benchmark around the globe for some time. Following the financial crisis of 2007-2009 and numerous LIBOR...

GlobalFinance and Banking
Sarah Wade
Sarah Wade
Samuel Brand
Samuel Brand
Garrett Fischer
Garrett Fischer
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The London Interbank Offered Rate ("LIBOR") has been the dominant interest rate benchmark around the globe for some time. Following the financial crisis of 2007-2009 and numerous LIBOR manipulation scandals, the U.K. Financial Conduct Authority ("FCA"), which regulates the administration of LIBOR, announced in 2017 that it would facilitate a transition away from LIBOR after 2021 and its publication would cease altogether after June 30, 2023. In response, the Office of the Comptroller of the Currency (the "OCC"), the Board of Governors of the Federal Reserve System (the "Board"), and the Federal Deposit Insurance Corporation (the "FDIC") issued an interagency statement encouraging U.S. banking organizations to avoid entering into new LIBOR based contracts after December 31, 2021.

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