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Let's Talk LIBOR
April 27, 2023

It’s hard to believe that, after more than six years, we can actually see the LIBOR finish line.

My esteemed colleague, Lary Stromfeld, has been banging drums from the outset and has certainly earned his market-leading reputation with his critically important work guiding the Federal Reserve ARRC, his drafting of New York State and federal LIBOR legislation, his counsel to many of our leading financial services clients, his thought leadership and his management of our LIBOR Preparedness Team.  

Lary has two items in today’s Cabinet News and Views − an update on the ARRC’s recent activities and an article on LIBOR he wrote for IFLR. Both are must reads as we get closer to the end of LIBOR as we know it.  

Lots more to read about this week. And by way of coming attractions, we are taking an in-depth look at the FSOC proposals on an analytic framework for financial stability risks and nonbank financial company determinations, and will have that out for next week’s edition. Also judging from the news out of Washington, it sounds as if we will be looking at the Federal Reserve’s (and possibly the FDIC’s) supervisory post-mortems on last month’s bank failures, and will provide thoughts on those next week as well.    

For now, please reach out here if there’s anything you’d like to talk about.   

Daniel Meade 
Partner and Editor, Cabinet News and Views

Profile photo of contributor Lary Stromfeld
Partner | Financial Regulation

The Alternative Reference Rates Committee announced three updates to its recommendations for the use of Term SOFR.

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Profile photo of contributor Lary Stromfeld
Partner | Financial Regulation

Since Andrew Bailey, then CEO of the UK’s Financial Conduct Authority, fired the starting gun in July 2017, regulators and market participants around the world have been planning for the end of LIBOR, which will now occur in less than 10 weeks. For many, this is the final leg of a marathon that has included many legal, economic and operational hurdles. For others, this will be an all-out sprint to the finish line. This article, originally published in IFLR, lays out some of the many considerations to meet the challenge of transitioning legacy contracts away from U.S. dollar LIBOR. Read it here.

Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Mercedes Kelley Tunstall
Partner | Financial Regulation

The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation provided supervisory guidance this week on certain overdraft practices. Of particular focus are “Authorize Positive, Settle Negative” (APSN) practices.

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The European Banking Authority has published a Consultation Paper on draft Guidelines on the simplicity, standardisation and transparency (“STS”) criteria for on-balance-sheet securitisations, comments on which are due by 7 July. Developed in accordance with a mandate set out at Article 26 of the Securitisation Regulation, the Draft Guidelines are intended to provide “a single point of consistent interpretation of the criteria on SST as well as on the credit protection agreement, third-party verification agent and synthetic excess spread applicable to STS on-balance-sheet securitisation.

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Profile photo of contributor Duncan Grieve
Special Counsel | White Collar Defense and Investigations
Profile photo of contributor Carl Hey
Associate | Real Estate

The UK Financial Conduct Authority has announced that its widely-anticipated Policy Statement in response to the Sustainable Disclosure Requirements and investment labels consultation will now be published in Q3 2023 instead of H1 2023, and that the proposed effective dates will be adjusted accordingly.

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Cadwalader continues to expand our Leveraged Finance & Private Credit team, as partner Smridhi Gulati has joined our firm in London.

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Mercedes Kelley Tunstall
Co-Editor, Partner
T. +1 202 862 2266
mercedes.tunstall@cwt.com

Alix Prentice
Co-Editor, Partner
T. +44 0 20 7170 8710
alix.prentice@cwt.com

Maurine R. Bartlett
Senior Counsel
T. +1 212 504 6218
maurine.bartlett@cwt.com

Sukhvir Basran
Partner
T. +44 0 20 7170 8620
sukhvir.basran@cwt.com

Brian Foster
Partner
T. +1 212 504 6736
brian.foster@cwt.com

James Frazier
Partner
T. +1 212 504 6963
james.frazier@cwt.com

Mark Howe
Partner
T. +1 202 862 2236
mark.howe@cwt.com

Gregg Jubin
Partner
T. +1 202 862 2485
gregg.jubin@cwt.com

Philip S. Khinda
Partner
T. +1 202 862 2262
philip.khinda@cwt.com

Andrew Karp
Partner
T. +1 212 504 6962
andrew.karp@cwt.com

Ivan Loncar
Partner
T. +1 212 504 6339
ivan.loncar@cwt.com

Peter Y. Malyshev
Partner
T. +1 202 862 2474
philip.khinda@cwt.com

Jed Miller
Partner
T. +1 212 504 6821
jed.miller@cwt.com

Michael Newell
Partner
T. +44 0 20 7170 8540
michael.newell@cwt.com

Richard M. Schetman
Senior Counsel
T. +1 212 504 6906
richard.schetman@cwt.com

Lary Stromfeld
Partner
T. +1 212 504 6291
lary.stromfeld@cwt.com

Jonathan M. Wainwright
Senior Counsel
T. +1 212 504 6122
jonathan.wainwright@cwt.com

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