The heads of the UK Financial Conduct Authority and the Federal
Reserve Bank of New York, acting as co-chairs of the Financial
Stability Board's ("FSB") Official Sector Steering
Group ("OSSG"), encouraged ISDA to seek market feedback on the
addition of a third "trigger event" in fallback language
that would trigger derivatives referencing IBOR floating rates to
move to the adjusted alternative rate. ISDA has indicated that it
would seek feedback for IBORs that were the subject of its
now-closed July 2018 Consultation, and is considering adding a
"pre-cessation" event in its upcoming consultation on USD
LIBOR and other IBORs not included in its earlier Consultation.
The OSSG co-chairs noted, "Without a trigger for this event
included in the ISDA definitions, market participants could find
themselves forced either to continue using LIBOR in legacy
contracts within a severely disrupted market or agree bilaterally
on terms at which they could close out across a wide array