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ARTICLE · 21 JULY 2020

SEC Identifies LIBOR Preparedness As An Examination Priority

A&O Shearman
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On June 18, 2020, the Securities Exchange Commission's (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused...

United StatesCorporate/Commercial Law
Donna Parisi
Donna Parisi
Geoffrey Goldman
Geoffrey Goldman
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Azam Aziz
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Mark Chorazak
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Lona Nallengara
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On June 18, 2020, the Securities Exchange Commission's (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused on LIBOR preparedness.1 OCIE has previously identified LIBOR preparedness of registrants (e.g., SEC-registered investment advisers, broker-dealers, investment companies, municipal advisors, transfer agents and clearing agencies) as a key examination priority for 2020, but the latest announcement offers specific insights into what information examiners will be seeking from registrants.2

Background

The expected cessation of LIBOR after 2021 is expected to significantly impact financial markets and present a multitude of financial, legal, operational, conduct and reputation risks for certain market participants. Preparing for the transition away from LIBOR to alternative rates is viewed as essential by a number of regulators, including the SEC. OCIE will be conducting

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