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ARTICLE · 03 JANUARY 2022

US CFTC Issues Further Technical No-Action Relief And Guidance For LIBOR Transition

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On December 22, 2021, in response to a request from the Alternative Reference Rate Committee (ARRC) and a further request from the Futures Industry Association (FIA)

United StatesFinance and Banking
J. Paul Forrester
J. Paul Forrester
Matthew Bisanz
Matthew Bisanz
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On December 22, 2021, in response to a request from the Alternative Reference Rate Committee (ARRC) and a further request from the Futures Industry Association (FIA), the United States Commodity Futures Trading Commission (CFTC) issued five technical no-action letters providing additional, and extending existing, time-limited, no-action relief and guidance for certain London Interbank Offered Rate (LIBOR) transition matters.

End-User Exception

In CFTC Staff Letter 21-26, the CFTC's Market Participants Division (MPD) amends and restates CFTC Staff Letter 20-23 to modify its discussion of the end-user exception to be consistent with a statement by the UK Financial Conduct Authority (FCA), which regulates ICE Benchmark Administration Limited, the administrator of ICE LIBOR. On March 5, 2021, the FCA confirmed that all LIBOR settings will either cease to be provided by any administrator or will no longer be representative (i) for all British Pound Sterling, Euro,

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