LIBOR and other IBORs are currently the focus of international and national reforms. The UK Financial Conduct Authority (‘FCA’), which regulates LIBOR, has stated that it will no longer compel banks to submit rates for the calculation of LIBOR after the end of 2021. The US Federal Reserve and other regulators have also taken measures to move markets away from IBORs within set timelines. As a result, the continuation of LIBOR and other IBORs on their current basis cannot be guaranteed after 31 December 2021.
These reforms may result in: (i) changes to the rules or methodologies used in calculating benchmark rates; (ii) restrictions on the use of benchmark rates; and/or (iii) discontinuance of benchmark rates. Even if certain benchmark rates might continue to be published, changes to their methodology, or restrictions on use, may mean that they are no longer representative of the underlying market and economic reality that the benchmark rate was originally intended measure or otherwise become no longer appropriate for products or agreements that customers have entered into with FAB.
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