FCA Ushers in the End of LIBOR

On March 5, 2021, the UK Financial Conduct Authority announced the dates that panel bank submissions for all LIBOR settings will cease, after which representative LIBOR rates will no longer be available.

After December 31, 2021, the FCA will no longer require panel banks to submit quotes for LIBOR settings other than overnight and 12-month U.S. dollar LIBOR and, after June 30, 2023, the FCA will no longer require panel banks to submit quotes for any U.S. dollar LIBOR settings. The FCA will consult on whether it should require LIBOR’s administrator, ICE Benchmark Administration, to publish certain “synthetic” rates for use in “tough legacy” contracts. The FCA announcement effectively triggers certain LIBOR “fallback” mechanisms, including those set forth in the recent protocol released by the International Swaps and Derivatives Association, Inc., underscoring the need for companies to complete their LIBOR transition plans.

Please click here to read the full alert memorandum.