ARTICLE
16 February 2021

OCC Releases LIBOR Preparedness Self-Assessment Tool

CW
Cadwalader, Wickersham & Taft LLP

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The OCC released a LIBOR Self-Assessment Tool for banks to use to consider the state of their LIBOR transition plans.
United States Finance and Banking

The OCC released a LIBOR Self-Assessment Tool for banks to use to consider the state of their LIBOR transition plans. The Self-Assessment Tool (in MS Word format) is a checklist of yes-or-no questions in the areas of (i) exposure assessment and planning, (ii) replacement rates, (iii) fallback language, and (iv) progress and oversight.

The OCC stated that LIBOR cessation preparedness plans should be "at least near completion," and reminded community banks of the agency's previous guidance and expectations in OCC Bulletins 2020-682020-98 and 2020-104. The OCC also noted that "not all sections or questions [of the Self-Assessment Tool] apply to all banks."

Primary Sources

  1. Libor Self-Assessment Tool
  2. OCC Bulletin 2021-7: Libor Transition - Self-Assessment Tool for Banks

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