Transitioning from Interbank Offered Rates (IBORs) to new Risk Free Rates (RFRs)* - Global Financial ...
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Transitioning from Interbank Offered Rates (IBORs) to new Risk Free Rates (RFRs)* March 2021 In recent years, international and domestic authorities alike have actively These documents have been updated from their previous versions worked with the private sector to address LIBOR’s shortcomings and to (June 2020) to provide the latest information regarding rates for major find alternative rates. In 2013, the International Organization of Securities currencies including the Australian dollar, Canadian dollar, Euro, Hong Commissions (IOSCO) developed an international set of principles Kong dollar, Japanese yen, Singapore dollar, Swiss franc, UK pound for financial benchmarks. These principles—which include 19 specific sterling and U.S. dollar. standards across governance, benchmark quality, methodology, and The information contained herein is based on the work of the FSB accountability—have emerged as the international standard. IOSCO has through the OSSG as well as other publicly available information. For rightly focused on tying benchmarks more closely to observable, arms- ongoing IBOR transition updates, please reference the individual central length transactions. bank working groups: The Financial Stability Board (FSB) and its members have published • Japanese yen: Study Group on Risk-Free Reference Rates and the proposals, plans, and timelines for reference rate reform and have Bank of Japan Cross-Industry Committee on Japanese Yen Interest promoted the strengthening of the major interest rate benchmarks. The Rate Benchmarks FSB and its members have been carrying out work on the development and introduction of alternative benchmarks, developing a plan to • Euro: Working Group on Euro Risk-Free Rates accomplish a transition to new benchmarks, encouraging work by the private sector on contract robustness, and reporting regularly on the • UK pound sterling: Working Group on Sterling Risk-Free Rates progress made. • U.S. dollar: Alternative Reference Rates Committee To aid in the awareness of the IBOR transition processes impacting • Swiss franc: National Working Group on Swiss Franc Reference Rates globally-active financial institutions, the Global Financial Markets Association (GFMA) has created the following documents outlining the ustralian dollar: Reserve Bank of Australia Market Operations Resources • A various parts and players. This information is organized into the enclosed four products: • Canadian dollar: Canadian Alternative Reference Rate Working Group 1. K ey Timelines and Milestones for the transition from IBORs to RFRs; • Singapore dollar: Steering Committee for SOR Transition to SORA 2. An overview of objectives for completing the transition in 2021; 3. S napshot of the IBOR and RFR variables associated with each currency; 4. ‘At a Glance’ Tracker of each official sector working group activities and near-term expected actions. *Current as of March 2021 1
IBORs to RFRs Transition Timeline This timeline lists key dates and milestones associated with the transition from IBORs to risk free rates for the Japanese yen, Euro, UK pound sterling, U.S. dollar, Swiss franc, Australian dollar, Canadian dollar, Hong Kong dollar and Singapore dollar. EMMI announces ECB publishes summary of EMMI receives license for the ABS, SFEMC, and SC-STS publish The FCA announces future cessation end to efforts on responses for the third public administration of Euribor from response to feedback on SGD and loss of representativeness of 35 EONIA reform. consultation by the working group the Belgian FSMA interest rate benchmarks consultation LIBOR benchmarks administered by Selects €STR as on Euro risk-free rates on the ICE and regulated by the FCA replacement for EONIA to ESTR legal action plan WG Euro RFR Publishes SC-STS publishes SORA EONIA Recommendations on the Market Compendium: Publication of Legal Action Plan for Transition HMT published EMMI concludes Transition from SOR to SORA compounded average from EONIA to €STR consultation recalibration of EONIA €STR for 1 week, 1 month, BoJ publishes on safe Cash Rate methodology as €STR + ECB publishes €STR 3 months, 6 months and 12 final report harbours methodology 8.5bp as of October 2019 months tenors ABS-SFEMC on the results and contract introduced WG publishes high level develops of its 2nd continuity Publication of a ‘Beta’ WG publishes responses MAS recommendations for proposal to consultation on in winding Term SONIA Reference to Term Sonia Reference establishes fallback provisions in Recommends strengthen down critical Rates (TSRR) consultation steerco to contracts for cash products the appropriate Rate for 1,3,6 and 12 month TONAR be SIBOR based benchmarks facilitate SOR and derivatives transactions choice and tenors expected by FTSE calculated by on consultation WG publishes “Next usage of JPY Russell, ICE Benchmark transition to referencing EURIBOR. Amendments to BOJ responses Steps” paper on interest rate Administration and Refinitiv SORA BMR published development of ABS, SFEMC, and SC-STS benchmarks in OJ Some TSRR and issuance PRA/FCA publish report announcing EONIA new EURIBOR of first SONIA-linked issues findings the discontinuation of Term SONIA for 1, 3, 6, business after tenors cease securitisation [retained of their “Dear enhanced SIBOR and its and 12 month tenors this date must to exist on balance sheet] CEO” letters. phased transition to SORA. available reference €STR May Dec Sept July Sept Nov Dec May June July Aug Oct Nov July Oct Nov Jan Feb April June Start of 2020 2020 2016 2016 2016 2017 2017 2018 2018 2018 2018 2018 2019 2019 2019 2019 2019 2019 2019 2020 2020 2021 2021 2021 2021 2021 2022 2022 Oct Apr Oct Mar Q2 April July Dec June July Sept Oct Dec Jan March End of Start of June 2017 2018 2018 2019 2019 2019 2019 2019 2020 2020 2020 2020 2020 2021 2021 2021 2022 2023 Fed Final Bank of CME and LCH NY State Legislature US bank regulators NWG presents a Canada begins complete passes bill to minimize previously publishes recommendations discussion paper on SOFR for fallback calculating discounting any potential legal announced probation SARON floating rate and publishing switch to uncertainty and adverse on use of LIBOR in Legend contract language notes addressing for FRNs, bilateral enhanced SOFR economic impacts new transactions by operational matters CORRA related to the transition YE 2021 JAPAN Recommends Recommends business loans, related to the timely SARON compounded syndicated determination IBA NWG announces FCA no longer E U SARON as term loans and of interest rate IBA publishes intends expected CHF LIBOR compels panel reference rate securitizations payments. consultation on to cease discontinuation by banks to submit UK potential LIBOR LIBOR quotes publication the end of 2021. cessation of Australia ARRC releases WGARR IBA intends to remaining a user guide publishes results Publication ISDA launches ISDA fallbacks cease publication of USD US for SOFR of consultation on of Bloomberg IBOR fallbacks supplement one week and two LIBOR Switzerland encouraging refinements for indicative supplement and protocol month USD LIBOR settings transition HONIA as ARR. fallback rates. and protocol take effect settings and all other Canada currency settings G20 publishes LIBOR’s regulator and its HK BIS releases a FSB publishes communique administrator confirm when LIBOR Transitional provisions of the primer on the new user guide for reaffirming end-2021 panels will cease. ISDA announces Benchmark Regulation expire. SG benchmark rates overnight RFRs transition deadline. setting of LIBOR spread adjustments. BMR comes into force O ther regulatory milestones 2
Completing the Transition in 2021 This timeline highlights the key mid-year and year-end objectives and milestones published by the Financial Stability Board (FSB) for all currencies. These milestones are outlined in further detail in the most recent FSB IBOR Transition Progress Report (published November 2020). We have also provided links to detailed final year transition plans for Japan, Singapore, Switzerland, the United Kingdom, and the United States1. Achieving these milestones and completing the transition in 2021 will require coordinated efforts from all financial market participants, including sell- and buy-side firms, infrastructure vendors, lenders, borrowers, and financial market infrastructure firms (FMIs). The information captured below is aimed to help clarify the near- term action items and milestones that all financial market participants should be managing towards. Firms should have completed a full assessment of their stock of legacy contracts, have determined which can be amended in advance of end-2021, and establish formalized plans to amend contracts in cases where counterparties agree. Firms should be fully prepared for LIBOR to cease. Where LIBOR linked exposure extends beyond end-2021, firms should make contact with counterparties to discuss All new business should be conducted in alternative how existing contracts may be impacted and what steps reference rates or be capable of switching to rates with may be needed to prepare for the use of alternative rates. limited notice. Start of 2021 Mid-Year 2021 Year-End 2021 Firms should have implemented the necessary system For any “tough legacy” contracts where amendments have and process changes required to enable the transition to not been possible, the implications of cessation or a lack alternative rates. of representativeness should have been considered and discussed between counterparties, and steps should have been taken to prepare for this outcome as needed. The Firms should aim to use robust alternative reference rates scope and impact of any steps taken by the official sector to LIBOR in all new contracts wherever possible. to support these “tough legacy” contracts, if available, should have been clearly understood and considered. Where realistic, firms should take steps to execute formalized plans to convert legacy LIBOR-linked contracts All firm business-critical systems and processes should be to alternative reference rates in advance of end-2021. conducted without reliance on LIBOR, or be capable of being changed to run without LIBOR with limited notice. Please find here links to detailed 2021 transition plans published by Japan, Singapore, Switzerland, the United Kingdom, and the United States1. 1 The ARRC’s Recommended Best Practices for Completing the Transition from LIBOR are important milestones even though not issued as supervisory guidance. 3
Snapshot: Variables of each IBOR and RFR by Jurisdiction The following lists out the key factors to be aware of in each IBOR and risk-free reference rate. Reformed IBOR include Alternative Alternative RFR Transaction Overnight Secured/ Underlying Rates Jurisdiction Benchmark IR Administrator waterfall RFR Administrator based? rate? Unsecured Transactions Published approach? JBA TIBOR JBA TIBOR EUROYEN Yes Yes Administration TIBOR TONA / Money Bank of Japan Yes Unsecured July 1985 TIBOR Markets Japan ICE Benchmark JPY LIBOR Administration Yes Yes (IBA) Euro short- term rate Yes October EONIA/ European Money (€STR) European Yes Money 2019 EURIBOR Markets Institute Yes Central Bank Unsecured (€STR) Markets (€STR) (EMMI) (ECB) EU Reformed Partly EURIBOR Reformed sterling ICE Benchmark overnight Bank of Money 23 April GBP LIBOR Administration Yes Yes Yes Unsecured index England Markets 2018 (IBA) UK average (SONIA) Secured Federal ICE Benchmark overnight Reserve Bank Repo USD LIBOR Administration Yes Yes Yes Secured 3 April 2018 financing of New York Transactions (IBA) US rate (SOFR) (FRBNY) Swiss ICE Benchmark average rate SIX Swiss Repo 25 August CHF LIBOR Administration Yes Yes Yes Secured overnight Exchange Transactions 2009 (IBA) (SARON) Switzerland 4
Snapshot: Variables of each IBOR and RFR by Jurisdiction The following lists out the key factors to be aware of in each IBOR and risk-free reference rate. Reformed IBOR include Alternative Alternative RFR Transaction Overnight Secured/ Underlying Rates Jurisdiction Benchmark IR Administrator waterfall RFR Administrator based? rate? Unsecured Transactions Published approach? Australian RBA Cash Reserve Bank Current Bank Bill Swap Cash Market Methodology Securities Yes Rate of Australia Yes Yes Unsecured Rate (BBSW) Transactions Introduced Exchange (ASX) (AONIA) (RBA) May 2016 Australia Thomson Enhanced Reuters – CORRA Bank of Repo CDOR Refinitiv No CORRA Yes Yes Secured began Canada Transactions Benchmark publication Canada Services June 2020 Overnight Hong Kong Interbank Hong Kong Enhanced Treasury Deals Treasury Markets HONIA HIBOR No HONIA Markets Yes Yes Unsecured Routed Association yet to be Association Through (TMA) published Hong Kong (TMA) Money Brokers Unsecured SIBOR overnight Monetary Published The Association interbank Authority of daily by of Banks in SORA Yes Yes Unsecured SGD Singapore MAS since Singapore (ABS) transactions (MAS) July 2005 Singapore SOR brokered in Singapore 5
At a Glance: Official Sector Working Group Activities and Near-Term Expectations This tracker follows the official sector working group activities, near-term expected actions, industry actions around cash fallback language, term rate statuses, and issuance of alternate RFRs to date. Working Working Group Alternative/New Cash Fallback Term Rate Near Term Expected Issuance to Group Structure RFR Status Language Status Status Actions Date The Cross-Industry December 2016: Future work plan for term Future work plan for term In November 2020, the Committee on Yen Interest Recommended reference rate based on Swaps reference rate based on Swaps Cross-Industry Committee Rate Benchmarks is divided Tokyo Overnight and Futures is discussed in the and Futures is discussed in the on JPY Interest Rate into three subgroups and Average Rate (TONA) subgroup for the development subgroup for the development Benchmarks published a one working group calculated by the of term reference rates. In of term reference rates. In detailed timeline of actions Bank of Japan focusing on: Bank of Japan. February 2020, Quick Corp February 2020, Quick Corp and objectives for 2021. Study Group was selected to prepare for was selected to prepare for on Risk-Free 1. Loans calculating and publishing calculating and publishing Reference Rates 2. Bonds prototype term rates. The prototype term rates. The Cross-Industry subgroup considers possible subgroup considers possible 3. Development of term Committee on timing of the implementation is timing of the implementation is reference rates Japanese Yen around mid-2021. around mid-2021. Interest Rate 4. Currency Swaps Recommended fallbacks for Benchmarks bond and loan products were outlined in the results of a Cross-Industry Committee on JPY Interest Rate Benchmarks consultation published in November 2020. The Euro Working Group September 2018: In February 2021, the WG In July 2019, the WG In March 2020, the There have been (WG) currently has four Recommended €STR published the results of announced a call to benchmark WG launched a public 7 issues of euro sub-groups, focusing on: to replace EONIA. consultations on EURIBOR administrators for expressions of consultation on swaptions floating rate notes fallback trigger events interest in administering €STR- impacted by the CCP which reference 1. Contract robustness February 2019: and €STR-based EURIBOR based forward-looking term discounting transition from €STR with total Working Group 2. Cash products and Euro WG confirms fallback rates. Feedback structures. In October 2020, EONIA to €STR. Based on volume of €4.85BN. on Euro Risk- derivatives EURIBOR will on these consultations the WG published feedback the responses received, the Free Rates continue for the will support the final relating to forward-looking term WG will evaluate potential 3. Financial accounting and medium term. recommendations on both structure methodology on €STR- recommendations. risk management November 2019: topics, to be published by the based EURIBOR fallback rates. Final recommendations on 4. Communication and EONIA will be euro risk-free rate working In March 2021, the European EURIBOR fallback trigger education discontinued Jan group in H1 2021. Central Bank (ECB) announced events and €STR-based 2022 as it is not BMR that it will start publishing EURIBOR fallback rates are compliant. compounded euro short-term expected to be published rate (€STR) average rates on by the euro risk-free rate 15 April 2021. The ECB intends working group in H1 2021. to publish compounded €STR average rates for 1 week, 1 month, 3 months, 6 months and 12 months tenors, via the Market Information Dissemination (MID) platform and through the ECB’s Statistical Data Warehouse (SDW). The announcement also confirmed the publication of a compounded index based €STR for the derivation of compounded rates for any nonstandard tenor. 6
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued) Working Working Group Alternative/New Cash Fallback Term Rate Near Term Expected Issuance to Group Structure RFR Status Language Status Status Actions Date The WG is broken April 2017: In September 2020, the WG In January 2021 Term SONIA In February 2021, the WG There have been 173 down into sub-groups Recommended published a recommendation became available from ICE published the latest version issues of sterling focusing on: reformed Sterling of credit adjusted spread Benchmark Administration and of its detailed roadmap for floating rate notes Overnight Index methodology for fallbacks Refinitiv. transition by end-2021. which reference 1. Bonds Bank of England Average (SONIA). in cash market products SONIA with total The BoE, FCA and WG End-Q1 2021 marks a Working Group 2. Loans referencing GBP LIBOR. volume of £75.1BN, encourage widespread adoption milestone for market on Sterling Risk- this is in addition 3. Communications ISDA has confirmed the LIBOR of SONIA compounded in participants to cease Free Rates to 49 securitisation & Outreach cessation announcement, by arrears in derivative markets initiation of new GBP deals referencing the BoE and FCA, will trigger and considered selected use LIBOR-linked loans, bonds, 4. Pension Funds & SONIA with total the fixing of the ‘spread cases for Term SONIA reference securitisations and linear Insurance Companies volume £28.3BN. adjustments’ to be used in its rates in cash markets, as derivatives (except for the 5. Infrastructure IBOR fallbacks. recommended by FICC Markets risk management of existing There are now Standards Board. positions that expire after numerous 6. Term Rates (Task Force) end-2021). Additionally, all originations of 7. Accounting/Tax (Task market participants are to SONIA-referenced Force) identify all legacy LIBOR loans in the sterling contracts expiring end- market, across both 8. R egulatory 2021, that can be actively syndicated and Dependencies (Task converted, and accelerate bilateral market Force) conversion where viable to sectors, after the reduce legacy volume. market opened in July 2019. The WG is broken June 2017: In June 2020, ARRC published ARRC is expected to work In March 2021, ARRC There have been down into sub-groups Recommended its final recommendations towards the development of a published a transition 1,667 issuances for focusing on: Secured Overnight on spread adjustment term reference rate. progress report which a combined total Financing Rate methodologies for fallbacks included objectives and amount of USD 1. Accounting/Tax The FRB published various sets Alternative (SOFR) as the RFR in cash products. These priorities for 2021. 1,196.4 BN. of data on indicative forward- Reference Rates 2. Business Loans to replace U.S. dollar recommendations were looking SOFR term rate data Committee LIBOR. developed after reviewing 3. Consumer Products (last update April 2019) (ARRC) responses to a supplemental April 2018: New York 4. Floating Rate Notes consultation on spread Federal Reserve adjustments. 5. Legal Bank (NYFRB) began publication of SOFR. 6. Market Structure and Paced Transition 7. Operations/Infrastructure 8. Outreach/ Communications 9. Regulatory Issues 10. Securitizations 11. Term Rate 7
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued) Working Working Group Alternative/New Cash Fallback Term Rate Near Term Expected Issuance to Group Structure RFR Status Language Status Status Actions Date The WG is broken October 2017: May 2020: WG has recommended using FINMA published a The first SARON- down into sub-groups Recommended Swiss The NWG discussed LIBOR compounded SARON wherever transition roadmap for linked public focusing on: Overnight Average end-scenarios and fallback possible 2021 to prepare for LIBOR’s issuance was Rate (SARON). language. The NWG end. This roadmap was in August 2019. 1. D erivatives & Capital recommended “to use the adapted to account for Issuance was for National Markets lookback method for CHF recommendations provided CHF 525 mm in Working Group 2. L oan and Deposit syndicated loans with an offset in the FSB’s 2021 roadmap. perpetual tier 1 on Swiss Franc Markets of 5 business days.” notes. Reference Rates The NWG has recommended market In the loan market, participants switch the first SARON- bilateral CHF LIBOR-based linked bilateral loan derivatives to SARON- was originated in based derivatives ahead of November 2019, end-2021. and in April / May 2020, multiple Swiss retail banks began offering SARON- linked residential mortgage loans. RBA recognizes three BBSW has been BBSW has been strengthened RBA and relevant regulators There have been working groups related strengthened and and will continue to be will continue to monitor 5 issuances for a to interest rate will continue to be published. both BBSW and AONIA. combined total benchmark reform. published going amount of AUD RBA evaluated that there Reserve Bank forward. 1.94 BN. 1. A SX BBSW Advisory are enough transactions to of Australia Committee focuses on AONIA is being determine BBSW and that it will Interest Rate BBSW Benchmark published as an RFR continue to exist as part of a Benchmark as part of a “multiple multi-rates approach. Reform Page 2. A ustralian Financial rates” approach. Markets Association (AFMA) focuses on promoting industry dialogue and information sharing 3. Australian Securitisation Forum (ASF) established a working group to consider benchmark reform on the Australian Securitisation Market 8
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued) Working Working Group Alternative/New Cash Fallback Term Rate Near Term Expected Issuance to Group Structure RFR Status Language Status Status Actions Date The Canadian Alternative CARR endorses an CARR developed Principles CDOR will continue to CARR will continue to There have been Reference Rate Working enhanced CORRA for Enhancements to Fallback exist as a part of a multiple rates support the adoption of, and 5 issuances for a Group (CARR) is based on the Language. Additionally, approach. transition to CORRA. combined total sponsored by the Canadian recommendations in November 2020, CARR amount of CAD In November 2020, CARR also In October 2020, CARR’s Fixed-Income Forum outlined in their published a consultation on 1.34 BN. published a consultation on mandate was expanded to Canadian (CFIF) which is a group set consultation paper CDOR fallback language for a proposed methodology for include an analysis of CDOR. Alternative up by the Bank of Canada. with no changes floating rate notes. calculating CORRA-in-arrears. Reference Rate Both groups are comprised based on responses. CARR is also expected to Working Group of market participants publish the results of its CFIF endorses and Bank of Canada consultation on calculating monitoring and representatives. CORRA-in-arrears and draft reviewing issues for fallback language for CDOR transition by the FRNs.” transition subgroup and by the benchmark admin. As HONIA’s administrator, The WGARR has HIBOR will continue to exist as a Technical adjustments may the TMA established an proposed technical part of a multiple rates approach. be made to HONIA based internal Working Group on refinements to HONIA upon the results of the 2019 TMA may also try to develop an Alternative Reference Rates outlined in an April consultation. OIS curve for HONIA depending (WGARR). 2019 consultation on market conditions and There are no plans to Hong Kong paper. demand. discontinue HIBOR and a Treasury Markets Refinements relate to multi rate approach will be Association the rate’s data source, adopted using both HONIA Working Group reporting window and and HIBOR. on Alternative publication time. Reference Rates In July 2020, HKMA “WGARR” In December published a circular providing 2019, TMA and an update on the status of WGARR published the transition and outlining the conclusion upcoming milestones. of the April 2019 consultation paper. SC-STS was established ABS-SFEMC identified In August 2020, ABS published Enhanced SIBOR will be SC-STS published its There have been by the Monetary Authority SORA as the a calculation methodology for discontinued and transitioned detailed roadmap of 11 issuances for a of Singapore (MAS) with alternative reference fallback rate (SOR)” to SORA. expected actions and combined total the Association of Banks in rate for SOR. objectives for 2021 amount of SGD The updated January 2021 Singapore (ABS) providing and 2022. 8.72BN. In July 2020, ABS- version of the SC-STS SOR Steering administrative support. SFEMC and SC-STC Transition to SORA FAQs Committee for SC-STS has four subgroups announced a decision for Corporates noted that SOR Transition focusing on: to discontinue the a forward-looking term to SORA (SC- 1. Derivatives new enhanced SIBOR SORA cannot be explored or STS) and also transition developed until there is deeper 2. B onds / Perpetual this market to and more liquid trading of Securities SORA. A summary SORA derivatives. This may be 3. B usiness / Syndicated of feedback on further explored as the market Loans the plan for this develops. discontinuation 4. Consumer Products was published in December 2020. 9
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