On 19 November 2019, the UK Financial Conduct Authority (the
"FCA") published "Questions and answers for firms
about conduct risk during LIBOR transition" (the
"Q&As") to remind firms of the conduct risks
associated with entering into LIBORreferencing transactions that
endure beyond end-2021. 1
It is now well-known that LIBOR is expected to cease after
end-2021, when the voluntary agreement of panel banks to continue
to submit to LIBOR ends. Firms and other market participants need
to have removed dependencies on LIBOR by this date to avoid
disruption when publication of LIBOR ceases. In anticipation of
firms increasing their efforts to transition away from the use of
LIBOR, the FCA has published the Q&As to identify potential
conduct issues arising from this transition under the following key
themes: (1) governance and accountability; (2) replacing LIBOR with
alternative rates in existing agreements and offering new products
based on risk free rates; (3)
