KNOWLEDGE

2021, the final year for LIBOR - It's the final countdown!

Morton Fraser Senior Solicitor Laura Purves
Author
Laura Purves
Associate
PUBLISHED:
29 January 2021
Audience:
category:
Blog

Now to some, those words will stir memories of singing out loud and interesting dancefloor moves! It certainly did for me!  But these are the words the FCA, the Bank of England and the Working Group on Sterling Risk-Free Reference Rates ("Working Group") have chosen to use in a joint press release published earlier this month to reinforce the fact that the end of LIBOR is near and that all involved need to be ready by the end of 2021, and preferably before. 

The time for action, if action hasn't been taken already, is now.  Both with regards to new business and legacy contracts, market participants must remove their reliance on LIBOR and actively transition away from it.  The message is loud and clear.

The Working Group has published an updated list of priorities along with an updated roadmap to support this and the number one top priority is for firms to be fully prepared for the end of GBP LIBOR by the end of 2021.  Their recommendation in relation to new business which will mature after the end of 2021 is that, from the end of March 2021, sterling LIBOR should not be used. 

Firms should also spend some time in what is left of Quarter 1 of 2021 to identify any legacy contracts on their books which mature after the end of 2021.  A process of active conversion of these contracts should be undertaken, should this be viable, with a view of concluding this process by the end of Quarter 3 of 2021.  If such a process was not viable, then robust fallbacks must be adopted where possible.

LIBOR's administrator, ICE Benchmark Administration ("IBA") published a consultation back in December 2020 on its intention to cease publication of not only the GBP LIBOR but also the EUR, CH, JPY and USD LIBOR on 31 December 2021 (30 June 2023 for USD LIBOR).  Feedback was requested by close of business on 25 January 2021 and IBA intend to publish a statement summarising feedback shortly thereafter.  This will be an interesting read, in particular in getting a feel for how prepared the market is at this stage of proceedings and how market participants are feeling about the transition, less than a year before the end of the calculation of interest rates as we know it.

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