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ARTICLE · 22 JULY 2020

Going Through Changes: Transitioning To A LIBOR-less World For Consumer Loans (Part II)

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In our January 27, 2020, Legal Update ("Part I"), we discussed the legal and regulatory issues faced by US consumer lenders and servicers as they prepare for the eventual transition away from LIBOR.

United StatesFinance and Banking
Laurence E. Platt
Laurence E. Platt
David Tallman
David Tallman
Francis L. Doorley
Francis L. Doorley
Christopher G. Smith
Christopher G. Smith
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In our January 27, 2020, Legal Update ("Part I"), we discussed the legal and regulatory issues faced by US consumer lenders and servicers as they prepare for the eventual transition away from LIBOR. In Part I, we noted that the question of how holders and servicers of adjustable-rate loans that use LIBOR as an index should proceed was largely unanswered at the time. Since then, Fannie Mae, Freddie Mac, and the Consumer Financial Protection Bureau ("CFPB") have all issued guidance to help ease the transition for originators, holders, and servicers as they navigate the quickly approaching post-LIBOR world. Below, we summarize this guidance.

I.GSE LIBOR Transition Playbook

To help lenders, servicers, and other market participants prepare for the transition away from LIBOR, Fannie Mae and Freddie Mac (the "GSEs") jointly issued a LIBOR Transition Playbook (the "Playbook") in May 2020 (which they subsequently updated in June 2020).1 The Playbook contains transition

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