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Legacy LIBOR
July 21, 2022

Just a couple of hours before our colleague Sophie Cuthbertson was scheduled to participate earlier this week in the LIBOR panel at SFVegas, the biggest structured finance conference in the U.S., the Federal Reserve issued a notice of proposed rulemaking − we all know it as an NPR − that provided guidance on identifying SOFR rates related to legacy contracts. With her deep knowledge of LIBOR and some last-minute cramming on the new Fed guidance that would have made her law professors proud, Sophie was able to incorporate some of this new thinking into her panel presentation.

While the June 30, 2023 end of LIBOR as we know it is no surprise, the regulators still have some work to do here, and so announcements like Tuesday's, even though anticipated in the industry, did create a bit of a scramble. We will continue to provide updates and guidance in the weeks and months to come. 

We also encourage you to read our "Cadwalader Corner Q&A" with Prof. Pete Hahn, highly respected in the financial services community in Europe as a former regulator, banker and academic at The London Institute of Banking & Finance. In particular, take a look at Prof. Hahn's views on fintech and cryptocurrencies.  

As always, we welcome your thoughts on this week’s issue of Cabinet News and Views and other timely topics. Just write to us here.

Daniel Meade and Michael Sholem
Co-Editors, Cabinet News and Views

Partner | Financial Regulation

On July 19, the Federal Reserve issued a notice of proposed rulemaking that would implement the Federal LIBOR Act. The NPR focuses primarily on identifying the particular version of SOFR that will apply to legacy contracts covered by the Act.

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Partner | Financial Regulation

The Consumer Financial Protection Bureau has issued several statements affecting the credit reporting industry in the last few months, including one on medical debts and one on auto financing, while at the same time emphasizing that the definition of a consumer reporting agency should be interpreted broadly to include not just credit reporting companies and tenant screeners but also “other data brokers.” 

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Partner | Financial Regulation

Once in a while, a Commodity Futures Trading Commission enforcement action confirms market participants’ worst fears that the CFTC is prepared to, and is able to, find violations of the Commodity Exchange Act where no such violations had previously existed. The July 19, 2022 CFTC settlement order involving Powerline Petroleum and its principals is one such case.

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Partner | Financial Regulation

On July 19, Federal Reserve Board Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal from the Federal Reserve Board, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency to modernize the Community Reinvestment Act.

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Partner | Financial Services

On July 20, the Financial Services and Markets Bill was introduced in the UK’s House of Commons. This first formal stage in the legislative process does not allow for debate of the Bill.

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Partner | Financial Regulation

On July 15, the Federal Deposit Insurance Corporation issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they are deposit brokers themselves.

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We were delighted to catch up last week with Pete Hahn, Emeritus Professor of Banking and Finance at The London Institute of Banking and Finance, for a chat on bank regulation, fintech and much more.

Read More »

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