Although a bedrock of the financial markets for over 30 years, LIBOR has been under pressure ever since the Wheatley Review, and a speech given by Andrew Bailey, Chief Executive of the UK’s Financial Conduct Authority (FCA) on July 27th heralds its potential demise. Market participants need to prepare for the possible transition away from LIBOR by the end of 2021. This briefing explains why and assesses the practical and documentary implications for the US market.
- UK regulatory support for LIBOR is likely to be withdrawn by the end of 2021.
- The development of suitable alternatives for
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On January 16, 2014, Clifford Chance released a briefing, available here, on exemptions for inter-affiliate and intragroup transactions under the U.S. Dodd-Frank Act and the European Market Infrastructure Regulation (“EMIR”). Both impose obligations requiring the clearing and reporting of certain derivative transactions and the margining of uncleared trades. However, there are differences as to how the U.S. and the EU regimes apply to inter-affiliate or intragroup transactions.
Our briefing summarizes and compares the relevant U.S. Commodity Futures Trading Commission (“CFTC”) rules against the relevant E.U. rules. It is not intended to be comprehensive or to provide legal advice.
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