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ARTICLE · 16 MARCH 2021

FRB Issues Guidance For Assessment Of LIBOR Transition Plans

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The Federal Reserve Board issued guidance for examiners who will assess supervised firms' LIBOR transition plans.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The Federal Reserve Board ("FRB") issued guidance for examiners who will assess supervised firms' LIBOR transition plans.

The FRB warned that "supervised firms that are not making adequate progress in transitioning away from LIBOR could create safety and soundness risks for themselves and for the financial system," and advised that "examiners should consider issuing supervisory findings and other supervisory actions if a firm is not ready to stop issuing LIBOR-based contracts by December 31, 2021."

The FRB recommended that examiners should assess whether the firm has (1) established a plan to transition away from LIBOR-based financial products, (2) accurately measured financial exposure and risk, (3) prepared for the operational adjustments to internal and vendor-provided systems, (4) identified contracts that reference LIBOR, (5) communicated sufficiently to clients on the LIBOR transition to comply with the Truth in Lending Act and (6) provided the LIBOR

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