
As we await the Federal Reserve Board to finalize the LIBOR transition regulations set forth in its notice of proposed rulemaking – Regulation Implementing the Adjustable Interest Rate (LIBOR) Act,[1] we are grateful[2] that on 23 November 2022 the Financial Conduct Authority (“FCA”) published Consultation Paper CP22/21: Consultation on ‘synthetic’ US dollar LIBOR and feedback to CP22/11 (“CP22/21”), in which it (a) proposes to require continued publication, under an unrepresentative “synthetic” methodology, of 1-, 3-, and 6-month USD LIBOR until the end of September 2024 and (b) announced that 3-month synthetic GBP LIBOR will continue to be published until the end of March 2024, after which each will cease permanently. Comments are requested on or prior to 6 January 2023.Continue Reading Thankful for Increasing Clarity on LIBOR’s Final Fate