Welcome to the latest issue of Mayer Brown's IBOR Transition Digest-a periodic compendium of global regulatory and market developments and insights on the complex issues confronting financial market participants as they plan to transition from LIBOR and its variants to replacement benchmark interest rates. As attention to IBORtransition accelerates and becomes more focused, it is critical to have access to comprehensive and timely resources about the market.

THOUGHT LEADERSHIP

Financial Regulators Clarify Key LIBOR Transition Considerations But Some Questions Remain
Eye on IBOR Transition, 22 October 2021

On 20 October 2021, in a Joint Statement on Managing the LIBOR Transition, the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, and State Bank and Credit Union Regulators emphasized their expectations that supervised institutions will transition away from LIBOR in an orderly fashion by the end of 2021. Transition preparedness will be an increasing area of supervisory focus and review.

NEWS AND DEVELOPMENTS

United States -  Syndicated and Bilateral Loans

LIBOR Transition Playbook
Fannie Mae and Freddie Mac, 15 October 2021

Updating the playbook for market changes since April 2021, including the availability of Term SOFR.

Playing SOFR-doku
Loan Syndications & Trading Association, 14 October 2021

Discussing the spread adjustment dynamics of the first loans emerging with SOFR as the initial interest rate, and reminding the market that the ARRC stated, in its January 2020 spread adjustment consultation, "the recommended spread adjustments would not and are not intended to apply to new contracts referencing SOFR."

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.