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).
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.
- 6 January 2023: ICMA response to FCA CP22/21 on ‘synthetic’ US dollar LIBOR
- September 2022: The transition of legacy US dollar LIBOR bonds under English law by Paul Richards
- 1 August 2022: ICMA response to FCA CP22/11 on winding down ‘synthetic’ sterling LIBOR and US dollar LIBOR
- 12 July 2022: Transition from LIBOR in the bond market, by Charlotte Bellamy and Katie Kelly, ICMA.
- 6 April 2022: The transition from LIBOR in the bond market: progress and remaining steps, by Paul Richards, ICMA.
- 12 January 2022: Transition from LIBOR to risk-free rates: Tough legacy bonds, Continued active transition of sterling LIBOR-linked legacy bonds, EU designation of synthetic LIBOR and Completion of SARON transition, by Charlotte Bellamy and Katie Kelly, ICMA.
- 20 October 2021: ICMA response to FCA CP 21/29 on proposed decisions on the use of LIBOR (Articles 23C and 21A BMR)
- 12 October 2021: The transition from LIBOR: “tough legacy” bonds, by Paul Richards, ICMA.
- 25 August 2021: ICMA response to FCA CP 21/19 on the proposed decision under Article 23D BMR for 6 sterling and yen LIBOR settings
- 20 August 2021: Follow-on announcement on Swiss Franc new issues being priced referencing SARON Mid-Swap Rate from 1 September 2021
- 16 July 2021: Announcement that Swiss Franc new issues will be priced referencing SARON Mid-Swap Rate from 1 September 2021
Key statements and publications
UK:
- December 2022: Summary minutes of the £RFRWG sub-groups and taskforce meetings, including the Bond Market Sub-Group meetings, are available here.
- November 2022: The FCA announced proposals that (i) the 3 synthetic yen LIBOR settings will cease at end-2022, (ii) the 1- and 6-month synthetic sterling LIBOR settings will cease at end-March 2023, (iii) the overnight and 12-month US dollar LIBOR settings will cease at end-June 2023, (iv) the 3-month synthetic sterling LIBOR setting will cease at end-March 2024 and (v) the 1-, 3- and 6-month synthetic US dollar LIBOR settings would cease at end-September 2024. The FCA also released a consultation requesting views on this proposal, and feedback on the proposed methodology for building the synthetic US dollar LIBOR settings, and what use of them should be allowed. The deadline for response to the consultation is 6 January 2022.
- 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.
View more...
US:
- 15 March 2023: The ARRC has released a readout from its meeting on 9 March 2023.
- 15 March 2023: The ARRC has released a paper formally stating its selections and recommendations as the “relevant governmental body” as they apply to the contractual provisions included in the ARRC’s recommended hardwired fallback language
- 13 March 2023: The Depository Trust & Clearing Corporation (DTCC) has launched a LIBOR Replacement Index Communication Tool, which is a tool for communicating rate and conforming changes for securities with CUSIPS.
View more...
Global:
- December 2022: The FSB has published a Progress Report on LIBOR and Other Benchmarks Transition Issues.
- 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.
View more...
Other jurisdictions:
- January 2023: The Euro RFRWG has published minutes of its meeting of December 2022
- 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.
General information and materials:
- FSB information and materials
- ESMA information and materials
- Financial Conduct Authority information and materials
- Working Group on euro risk-free rates information and materials
- Cross-Industry Committee on Japanese Yen Interest Rate Benchmarks information and materials
- Working Group on Sterling Risk-Free Rates information and materials
- The National Working Group on Swiss Franc Reference Rates information and materials
- US dollars: Alternative Reference Rates Committee 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
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
19 January 2023
Minutes of LIBOR Trade Association Working Party Meetings
13 October 2022
Minutes of LIBOR Trade Association Working Party Meetings
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
- March 2022
- January 2022
- December 2021
- November 2021
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- April 2021
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- December 2020
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- November 2019
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- September 2019
- July 2019
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- January 2019
- December 2018
- November 2018
- October 2018
- September 2018
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