In separate statements (see here and here), the Financial Conduct Authority (the
"FCA") and ICE Benchmark Administration (the
"IBA") responded to ISDA's December 2019 letter
requesting confirmation that the "reasonable period"
during which LIBOR would continue to be published following an
announcement from the FCA that LIBOR is no longer representative
would be minimal (i.e., months rather than years).
FCA Response
The FCA urged market participants to expect non-representative
LIBOR to be published for a period no greater than a few months. In
its statement, the FCA encouraged ISDA to allow derivatives market
participants to include pre-cessation fallback triggers in their
derivative contracts. The FCA also reaffirmed its stance that it
will not seek to sustain LIBOR beyond the end of 2021 by requiring
panel banks to make submissions.
