It has been more than two years since the U.K.'s Financial
Conduct Authority announced that after the end of 2021, it will not
compel any banks to provide quotations upon which LIBOR is based.
This announcement gave the markets notice that by that date, all
financial products linked to LIBOR—a reported $350 trillion
worth—should be migrated to alternative reference rates. This
is a mammoth transition project for the financial markets, and some
progress has been made—a likely LIBOR successor for U.S.
dollars has been identified, and U.S. banks have begun assessing
their LIBOR exposures—but an enormous amount of work remains
to be done. The transition has many moving parts, each of them
presenting potential legal risk.
