On February 10, 2021, the Office of the Comptroller of the Currency (the “OCC”) published OCC Bulletin 2021-7, Libor Transition: Self-Assessment Tool for Banks, in order to help OCC-regulated financial institutions to identify and mitigate risks related to preparedness for the expected cessation of the London InterBank Offered Rate (“LIBOR”).

A checklist styled Self-Assessment Tool accompanies the Bulletin and consists of 37 questions across four general subject areas that each have one or more overarching questions as an objective.   
Continue Reading OCC Publishes LIBOR Self-Assessment Tool for Banks

On February 5, the International Swaps and Derivatives Association (“ISDA“) announced that it will seek additional information from market participants about the development of contractual language that can be used to replace references to LIBOR and other interbank offered rates in swaps and other the over-the-counter (“OTC“) derivative contracts.  ISDA refers to this replacement contractual language as “fallback language”.

On February 6, ISDA provided an updated timeline that relates to the development and implementation of this fallback language.  Also, ISDA confirmed that buy-side firms will not be charged a fee, if they adhere to the final fallback protocol within three months of its publication.

This post will provide additional information about these two developments.

Continue Reading LIBOR Transition Planning: ISDA Makes Important Annoucements About LIBOR Replacement Language for Swaps