ICMA has been engaging with the official sector and members on the global issue of benchmark reform for several years.

ICMA’s focus has centred on the development of Risk-Free Reference Rates (RFRs)1, and the transition of legacy LIBOR bonds to RFRs, either by way of a market-based solution to actively transition them, or by way of legislation.

  • A significant milestone was achieved on 31 December 2021 when most LIBOR settings2 were published for the final time.
  • The UK enacted enabling legislation to facilitate a form of ‘synthetic’ 1 month, 3 month and 6 month sterling and JPY LIBOR, which will continue to be published on a temporary basis.
  • US dollar LIBOR is expected to cease on 30 June 2023. A US federal legislative solution establishes a clear and uniform process for replacing US dollar LIBOR in existing contracts where the terms do not provide for the use of a clearly defined or practicable replacement.
  • ICMA’s attention is now turning towards legacy US dollar LIBOR bonds governed by English and other non-US laws.

ICMA is a member of the Working Group on Sterling Risk-Free Reference Rates, with Paul Richards (Head of Market Practice and Regulatory Policy, ICMA) chairing a sub-group focusing on benchmark issues in bond markets. ICMA is also a non-voting member of the Working group on euro risk-free rates and participated in the National Working Group on Swiss Franc Reference Rates3.

(1 RFRs were developed in response to recommendations by the Financial Stability Board (FSB) to increase confidence in the reliability and integrity of interest rate benchmarks).
(2 including sterling, Japanese yen, Swiss franc and euro LIBOR).
(3 This group has since been dissolved due to the successful replacement of Swiss franc LIBOR).

Key recent materials
Other materials
Joint trade association materials
Key recent materials

Set out below is a list of ICMA briefings and releases on the global transition to RFRs, together with links to ICMA and official sector information and other materials. In addition, benchmark-related resources in selected Asia-Pacific markets are available on this ICMA webpage.



ICMA materials

               

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Key statements and publications

UK: 

  • September 2022: The FCA announced its decision to require continued publication of the 1- and 6-month synthetic sterling LIBOR settings until end-March 2023, after which these settings will permanently cease. They are also considering responses on when the 3-month synthetic sterling LIBOR setting could cease in an orderly fashion, and on remaining exposures to US dollar LIBOR, and expect to provide a summary of the feedback received and their response later in 2022.
  • September 2022: Summary minutes of the recent Bond Market Sub-Group and Loan Enablers Task Force meetings are available on the RFRWG website here.
  • August 2022: The FCE released a statement for issuers and bondholders of outstanding LIBOR-linked bonds, strongly encouraging issuers and bondholders to take the necessary action to transition outstanding LIBOR-linked bonds to fair alternative rates.

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US:

  • 11 July 2022: The ARRC has welcomed a statement by Refinitiv that it intends to begin publishing ARRC-recommended fallback rates based on the CME Term SOFR rates in September 2022.
  • 11 July 2022: The ARRC has released a LIBOR Legacy Playbook, a guide describing the existing broad frameworks to support the transition of legacy LIBOR cash products. The guide aims to provide tools and resources, including a compilation of best practice recommendations and reference materials, to assist market participants in ensuring that the transition from LIBOR is operationally successful.
  • June 2022: The ARRC has released a set of recommendations for contracts linked to USD LIBOR ICE Swap Rates (USD LIBOR ISR) including a suggested fallback formula that can be used for USD LIBOR ISR fixings after 3-month USD LIBOR has been discontinued or becomes non-representative.

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Global:

  • November 2021: The FSB have released a Statement to Support Preparations for LIBOR Cessation, in which they urge market participants to act urgently to complete any remaining steps from the FSB’s global roadmap. The Statement encourages adoption of overnight RFRs as opposed to any other rates, and stresses that active transition of legacy contracts remains the best way for market participants to have control and certainty over their existing agreements.

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Other jurisdictions:

  • September 2022: The Working Group on Euro Risk-Free Rates has published a recommendation that all reasonable steps should be taken to make derivatives referencing the €STR benchmark available to customers. The recommendation also reminds market participants that backward looking rates such as compounded €STR average rates are already available for all products including loans, bonds and other cash instruments.
  • July 2022: The Euro RFRWG has published minutes of its meeting of 17 June
  • April 2022: The Euro RFRWG has published minutes of its meeting on Wednesday 2 March 2022.
  • November 2021: The Financial Services Agency (FSA) and Bank of Japan (BOJ) released a statement on the use of synthetic yen LIBOR in response to the Final Report on the Results of the Public Consultation on the Treatment of Tough Legacy Contracts in Japan published by the Cross-Industry Committee on Japanese Yen Interest Rate Benchmarks.
  • November 2021: The National Working Group on Swiss Franc Reference Rates published minutes of its November 2021 meeting.

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General information and materials:

 




Contacts:

Paul Richards
Managing Director, Head of Market Practice and Regulatory Policy; Member of ICMA's Executive Committee  
Direct line: +44 20 7213 0315

Katie Kelly
Senior Director, Market Practice and Regulatory Policy; Secretary to the ICMA Financial Institution Issuer Forum (FIIF) and to the ICMA Corporate Issuer Forum (CIF).
Direct line: +44 20 7213 0331

Charlotte Bellamy
Senior Director, Market Practice and Regulatory Policy; secretary to the ICMA Legal & Documentation Committee (LDC) and related groups.
Direct line: +44 20 7213 0340

Other materials

January 2022
ICMSA Bulletin - Synthetic LIBOR, type 1 fallbacks an dealer poll mechanisms

May 2021
ICMSA Bulletin – The role of Calculation Agents and Benchmark Agents/Independent Advisors

January 2021
ICMSA Bulletin on the discontinuation of LIBOR/IBORS – implications for English-law note trustees and agency roles – Update – Legacy Transactions

January 2021
ICMSA Bulletin on the discontinuation of LIBOR/IBORS – operational and procedural considerations for Consent Solicitations and Written Resolutions

June 2020
ICMSA Bulletin on the discontinuation of LIBOR/IBORs – timeline of a consent solicitation

March 2020
ICMSA Bulletin on different approaches for IBOR transition under English law trust deeds and New York law indentures

January 2020
ICMSA Bulletin 200120/47 – Benchmark replacement and fallback provisions – Key principles and guidelines for agents and trustees

18 January 2019
ICMSA Bulletin 190118/45: The discontinuation of LIBOR/IBORS - implications for English-law agency roles

1 November 2018
ICMA and SIX Joint Conference - LIBOR to SARON: Are you ready?
Presentations given at this event are available on the ICMA event webpage.

18 October 2018
ICMSA Bulletin 81018/44: Implications for English law Trustees on discontinuation of LIBOR/IBORs

15 February 2017
ICMA response to the ICE Benchmark Administration Limited Additional Consultation on ICE LIBOR Evolution

31 March 2016
ICMA response to ESMA Discussion Paper on Benchmarks Regulation

29 January 2016
ICMA response to EMMI Consultative Position Paper on the Evolution of Euribor

16 October 2015
ICMA response to the ICE Benchmark Administration Limited Second Position Paper on the Evolution of ICE LIBOR

19 September 2014
ICMA response to the ICE Benchmark Administration Error Policy Consultation

29 November 2013
ICMA response to to ILOC / BBALIBOR Joint Consultation Paper on LIBOR Re-fixing

16 May 2013
ICMA response to IOSCO’s consultation on "Principles for Financial Benchmarks"

11 February 2013
ICMA response to IOSCO’s consultation on "Financial Benchmarks"
ICMA response to ESMA-EBA’s joint consultation on “Principles for Benchmark Setting Processes in the EU”

6 December 2012
ICMA response to the BBA’s consultation on "Strengthening LIBOR"

27 November 2012
ICMA response to the European Commission’s "Consultation Document on the Regulation of Indices"

7 September 2012
ICMA submission in relation to the August 2012 initial discussion paper “The Wheatley Review of LIBOR”




Contacts:

Paul Richards
Managing Director, Head of Market Practice and Regulatory Policy; Member of ICMA's Executive Committee  
Direct line: +44 20 7213 0315

Katie Kelly
Senior Director, Market Practice and Regulatory Policy; Secretary to the ICMA Financial Institution Issuer Forum (FIIF) and to the ICMA Corporate Issuer Forum (CIF).
Direct line: +44 20 7213 0331

Charlotte Bellamy
Senior Director, Market Practice and Regulatory Policy; secretary to the ICMA Legal & Documentation Committee (LDC) and related groups.
Direct line: +44 20 7213 0340

Joint trade association materials

20 November 2020
Joint trade association letter regarding the third country transitional provisions of the EU Benchmarks Regulation

20 January 2020
APLMA, ASIFMA, ICMA, ISDA and KPMG held a webcast covering all aspects of LIBOR transition readiness, especially as it pertains to Asia-Pacific jurisdictions. This session focused on issues relevant for buy-side firms and corporate treasurers, such as debt issuance, interest rate derivatives hedging, and debt instruments held by investment managers.

25 June 2018
IBOR Global Benchmark Report 2018
Download the press release

1 February 2018
IBOR Global Benchmark Survey 2018 Transition Roadmap
Download the press release

31 January 2018
Joint trade association letter to the FSB regarding implementation of risk free rates and transition away from LIBOR: key issues for the global financial markets




Minutes of LIBOR Trade Association Working Party Meetings

 



Contacts:

Paul Richards
Managing Director, Head of Market Practice and Regulatory Policy; Member of ICMA's Executive Committee  
Direct line: +44 20 7213 0315

Katie Kelly
Senior Director, Market Practice and Regulatory Policy; Secretary to the ICMA Financial Institution Issuer Forum (FIIF) and to the ICMA Corporate Issuer Forum (CIF).
Direct line: +44 20 7213 0331

Charlotte Bellamy
Senior Director, Market Practice and Regulatory Policy; secretary to the ICMA Legal & Documentation Committee (LDC) and related groups.
Direct line: +44 20 7213 0340

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