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Adherence to the ISDA Protocol

London Interbank Offer Rates (LIBOR) and other Interbank Offer Rates (collectively, IBORs) are expected to be discontinued after 31 December 2021 and replaced with certain Alternative Reference Rates (ARRs), with the exception of certain USD LIBOR rates which are expected to be discontinued on 30 June 2023 . LIBOR and IBOR rates typically underpin a significant proportion of derivatives transactions including, potentially, a material proportion of your derivative transactions.


The International Swaps and Derivatives Association (ISDA), has launched the ISDA 2020 IBOR Fallbacks Protocol (the ISDA Protocol) to facilitate the smooth transition away from IBORs to ARRs, as well as a supplement to the 2006 ISDA Definitions (the Supplement). FAB has adhered to the ISDA Protocol. FAB encourages all of its clients to inform themselves about the ISDA Protocol and the Supplement and consider whether it would be appropriate for them to adhere to the ISDA Protocol. FAB has prepared this communication to highlight publicly available information about the ISDA Protocol and the Supplement, in order to further inform your decision-making process.

Many leading regulators and industry groups2345 are encouraging market participants to adhere to the ISDA Protocol as one of the key milestones to transition away from IBORs.

For more information on the ISDA Protocol and Fallbacks, please click here.


Important Notice:

This communication does not necessarily deal with every important topic or cover every aspect of the topics with which it deals. It is not designed to provide legal, financial or other advice. By reviewing this communication, you agree that FAB is not acting as your advisor and is not providing legal or financial advice or making any recommendation to adhere to the ISDA 2020 IBOR Fallbacks Protocol; it being understood that any information or explanations pertaining to the terms of ISDA 2020 IBOR Fallbacks Protocol provided via this communication shall not be considered legal or financial advice or a recommendation to enter into same.

Each recipient of this communication will make its own independent decisions regarding whether to adhere to ISDA 2020 IBOR Fallbacks Protocol and as to whether such protocol is appropriate or proper for it based upon its own judgement and upon advice from such advisors as it has deemed necessary.

Any information which is provided on IBORs in this document should be read in conjunction with About IBOR Transition (Conventional Products) and About IBOR Transition (Islamic Products).

  1. The ICE Benchmark Administrator (IBA) has released a consultation on discontinuing one-week and two-month USD LIBOR with effect from 31 December 2021, but has proposed to extend the cessation dates for the publication of O/N, 1M, 3M, 6M and 12M USD LIBORs to 30 June 2023.
  2. Alternative Reference Rates Committee
  3. Financial Stability Board
  4. The Working Group on Sterling Risk-Free Reference Rates, the Financial Conduct Authority and the Bank of England
  5. The working group on euro risk-free rates, the European Central Bank, the European Securities and Markets Authority, the European Commission and the Financial Services and Markets Authority

FAB does not accept any responsibility for, and shall not have any liability with respect to, the administration, submission or any other matter related to benchmark rates such as IBORs or any alternative rate including, without limitation, whether the composition or characteristics of any alternative rate will be similar to, or produce the same value or economic equivalence as, the original benchmark rates (including IBORs) or whether any alternative rate will have the same volume or liquidity as the original benchmark rate prior to its discontinuance or unavailability.

Except where we otherwise agree with you in writing, FAB does not provide advice, or recommendations on the suitability of your product choice or financing solution. You should consider whether you need to obtain professional independent advice (legal, financial or otherwise), prior to entering into any agreement or investing in a product which references a benchmark rate such as an IBOR. FAB does not owe you any duties or have any liability to you in relation to its management of the transition from IBOR benchmark rates to alternative rates. FAB is not under an obligation to update the information in this explanation and general risk warning.