Transitioning from Interbank Offered Rates (IBORs) to new Risk Free Rates (RFRs)

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Transitioning from Interbank Offered Rates
(IBORs) to new Risk Free Rates (RFRs)*
June 2020

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           (September 2019) to provide the latest information regarding rates for
find alternative rates. In 2013, the International Organization of Securities   major currencies including the Australian dollar, Canadian dollar, Euro,
Commissions (IOSCO) developed an international set of principles                Hong Kong dollar, Japanese yen, Singapore dollar, Swiss franc, UK pound
for financial benchmarks. These principles—which include 19 specific            sterling and U.S. dollar. This version also includes a new document
standards across governance, benchmark quality, methodology, and                highlighting 2020 objectives and milestones published by the UK and US
accountability—have emerged as the international standard. IOSCO has            working groups.
rightly focused on tying benchmarks more closely to observable, arms-
                                                                                The information contained herein is based on the work of the FSB
length transactions.
                                                                                through the OSSG as well as other publicly available information. For
The Financial Stability Board (FSB) and its members have published              ongoing IBOR transition updates, please reference the individual central
proposals, plans, and timelines for reference rate reform and have              bank working groups:
promoted the strengthening of the major interest rate benchmarks. The
                                                                                • Japanese yen: Study Group on Risk-Free Reference Rates and the
FSB and its members have been carrying out work on the development
                                                                                  Bank of Japan Cross-Industry Committee on Japanese Yen Interest
and introduction of alternative benchmarks, developing a plan to
                                                                                  Rate Benchmarks
accomplish a transition to new benchmarks, encouraging work by the
private sector on contract robustness, and reporting regularly on the           • Euro: Working Group on Euro Risk-Free Rates
progress made.
                                                                                • UK pound sterling: Working Group on Sterling Risk-Free Rates
To aid in the awareness of the IBOR transition processes impacting
globally-active financial institutions, the Global Financial Markets            • U.S. dollar: Alternative Reference Rates Committee
Association (GFMA) has created the following documents outlining the
                                                                                • Swiss franc: National Working Group on Swiss Franc Reference Rates
various parts and players. This information is organized into the enclosed
four products:                                                                     ustralian dollar: Reserve Bank of Australia Market Operations Resources
                                                                                • A

1. K
    ey Timelines and Milestones for the transition from IBORs to RFRs;         • Canadian dollar: Canadian Alternative Reference Rate Working Group

2. 2020 Objectives and Milestones;                                             • Singapore dollar: Steering Committee for SOR Transition to SORA

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 June 2020

                                                                                                                                                           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.

                                                                                  ECB publishes               BoJ publishes public          FCA, BoE, and UK RFR WG publish
                                                                                  summary of responses        consultation on the           statement on impact of COVID-19:
                                                                                  for the third public        appropriate choice and        central assumption that firms cannot
                                                                                                                                                                                     Legend
                                                                                  consultation by the         usage of Japanese Yen         rely on LIBOR being published after         JAPAN
    Recommends                                                                    working group on            Interest rate benchmarks end-2021 is unchanged.
                                              EMMI announces end                  Euro risk-free rates on
    TONAR be                                                                                                                                                                            E
                                                                                                                                                                                        U
                                              to efforts on EONIA                 the EONIA to ESTR         EMMI receives license for the
    calculated by BOJ
                                              reform. Selects €STR as             legal action plan         administration of Euribor from
                                              replacement for EONIA                                         the Belgian FSMA                                                            UK
                                                                                                                                                    Bank of Canada
                   Some                                                          EMMI concludes                                                     to begin
                                                                                 recalibration              WG   Euro RFR   Publishes                                                   Australia
   Cash Rate       EURIBOR                                                                                                                          calculating
                                                     WG publishes                of EONIA                   Recommendations on the                  and publishing
   methodology     tenors cease                                                                             Legal Action Plan for Transition                                            US
                                                     responses to Term           methodology as                                                     enhanced CORRA
   introduced      to exist                                                                                 from EONIA to €STR
                                                     Sonia Reference Rates       €STR + 8.5bp as
                                                     (TSRR) consultation                                                                                                                Switzerland
                                                                                 of October 2019
                                                                                                                    ECB publishes €STR
                                                            WG publishes “Next              WG releases
                                                                                                                                                                                        Canada
                                                                                                                          WG publishes high
                                                            Steps” paper on                 transition                    level recommendations                                         HK
                                                            development of                  roadmap and                   for fallback provisions
                                                            TSRR and issuance               PRA/FCA                       in contracts for                                              SG
                                                                                                                                                         Provisional
                                                            of first SONIA-linked           issues findings               cash products and              live term
                                                            securitisation [retained        of their “Dear                derivatives transactions                                      O
                                                                                                                                                                                         ther regulatory
                                                                                                                                                         SONIA to be
                                                            on balance sheet]               CEO” letters.                 referencing EURIBOR.                                          milestones
                                                                                                                                                         published

      May Dec           Sept                    Sept   Nov Dec                              May June         July   Oct Nov              March June    Q3
2016 2016 2016 2017 2017         2018           2018   2018 2018   2019                     2019 2019        2019   2019 2019    2020 2020 2020 2020                 2021                    2022

                         Oct Dec Apr July           Oct               Mar       Q2      April            July    Aug         Dec       Q2         July  Oct Nov          Q1         Q2 End of    Start of
                         2017 2017 2018 2018        2018              2019     2019     2019             2019    2019        2019     2020        2020 2020 2020        2021       2021 2021      2022

                                  Fed                                                                         MAS establishes                          CME and              Expect
                                                                          Final recommendations
                                  publishes                                                                   steerco to facilitate                    LCH plan             term
                                                                          for fallback contract
                                  SOFR                                                                        SOR transition to SORA                   discounting          publication
                                                                          language for FRNs,
                                                                          bilateral business                  ABS-SFEMC issues                         switch to            of SOFR          Transitional
                                                                          loans, syndicated loans             consultation on SORA                     SOFR                                  provisions of
                               ABS-SFEMC
                               issues                                     and securitizations                 transition from SOR                                                            the Benchmark
                               consultation                                                                                                                                                  Regulation
            Recommends                             Recommends                                           NWG presents a discussion                                                            expire. BMR
                               on enhancing                                  ARRC releases a
            SARON                                  compounded                                           paper on SARON floating                                                              comes into force
                               SIBOR                                         user guide for SOFR                                                                      Data collection
                                                   SARON as term                                        rate notes addressing
                                                                             encouraging transition                                       Expected publication        begins on
                                                   reference rate                                       operational matters related
                                                                                                        to the timely determination       of amendments               model-ability          EONIA new
                         ABS-SFEMC develops                                                             of interest rate payments.        to 2006 ISDA                criteria for           business after
                         proposal to strengthen                              WGARR releases                                               Definitions and             FRTB                   this date must
                         SIBOR based on                                      consultation on            WGARR publishes results of        related protocol            implementation         reference €STR
                         consultation responses                              refinements for            consultation on refinements
                                                                             HONIA as ARR               for HONIA as ARR.                      Expected date of          FCA no longer
                                                                                                                                               effectiveness for         compels panel
                                                                BIS releases a                  FSB publishes        Publication of            amendment to 2006         banks to
                                                                primer on the new               user guide for       Bloomberg indicative      ISDA Definitions and      submit LIBOR
                                                                benchmark rates                 overnight RFRs       fallback rates.           related protocol          quotes

                                                                                                                                                                                                              2
2020 Objectives and Milestones
This timeline highlights the key objectives and milestones published by the risk free rates working groups
from the United Kingdom and United States. Achieving these milestones and completing the transition in
2021 will required coordinated efforts from all financial market participants, including sell- and buy-side
firms, infrastructure vendors1, lenders, borrowers, investors and Financial Market Infrastructure firms (FMIs).                                                                                       Legend
The information captured below is aimed to help clarify the near-term milestones that all financial market
participants should be managing towards.                                                                                                                                                                 UK
                                                                                                                       Cease issuance of GBP LIBOR-based cash                                            US
                                                                                                                       products maturing beyond 2021 (Postponed
                                                                                                                       to end of Q1 2021 due to COVID-19)                                                G
                                                                                                                                                                                                          eneral Updates
            Statement of 2020 RFR WG priorities and
            supporting documents including: factsheet                                                                                 Lenders should be able to offer                                    C
                                                                                                                                                                                                          CPs
            for end users, consent solicitation                                                                                       non-LIBOR linked products.
            statement, term rate use case paper.
                                                                                                                                                                           Lenders, working with
                                                                                                                           Target for key infrastructure available         borrowers, should include clear
            Swaption conventions                                                                                           from Treasury Management Systems and            contractual arrangements for all
            survey feedback published.                                   Summary feedback published for                    loans vendors to use compounded SONIA           new and re-financed LIBOR loan
                                                                         cash credit spread adjustment.                                                                    products to facilitate conversion
            Encouraged convention change from                                                                                   Target that end-users of loan              prior to the end of 2021.
            LIBOR to SONIA on 2 March 2020.                              Cash legacy transition paper to                        systems are ready to support SONIA
                                                                         be published.                                          syndicated loans and that critical                   Develop a clear framework for
            Loans Enablers Task Force publishes path to                                                                         internal dependencies are addressed                  managing transition of legacy
            discontinuation of new GBP LIBOR lending                             Publication of a Paper on                                                                           LIBOR products, to significantly
            by end of Q3 2020 (deadline postponed to                             the identification of Tough                   Provisional live Term                                 reduce the stock of GBP LIBOR
            end Q1 2021 due to COVID-19).                                        Legacy Issues                                 Rate to be published.                                 referencing contracts by Q1 2021.

             Q1                                                          Q2                              May                    Q3                             End Q3        Q4                                   End
2020        2020                                                        2020                            2020                   2020                             2020        2020                                 2020     2021

                                              March 11,                                          June      End June               July July 31,            End Sept                   Oct                Nov          End
                                               2020                                              2020        2020                 2020 2020                 2020                     2020               2020         2020

                                   WHO declares                GSEs to offer SOFR-indexed CMOs2                              Establish final      Develop RFP process and             CME and         Expected that
                                   COVID-19 a                                                                                recommended          criteria for recommendations for    LCH plan        amendments to
                                   pandemic.                   Publish revisions to the ARRC hardwired                       conventions for      selecting an administrator of an    discounting     the 2006 ISDA
                                                               fallback language, recommended                                SOFR-based           AARC-recommended forward-           switch to       Definitions and
                                                               conventions, and supporting materials                         FRNs, business       looking term SOFR Rate.             SOFR            related protocol
                                                               for business loans.                                           loans, and                                                               go into effect
                                                                                                                             securitizations.     Establish RFP process for selection of an
                                                                                                                                                  administrator to publish ARRC-recommended           Best Practices – Vendors
                                                               Publish recommended fallback language
                                                                                                                            Expected              spread adjustments and spread-adjusted              should be ready to
                                                               for new student loans referencing LIBOR
                                                                                                                            publication of        rates and to finalize technical details for         support SOFR for
                                                               and conventions for new student loans
                                                                                                                            amendments to         related recommended spread adjustments.             securitizations; No new
                                                               referencing SOFR.
                                                                                                                            the 2006 ISDA                                                             LIBOR FRNs maturing
                                                                                                                            Definitions and       Establish resource guides identifying               after 2021; Dealers should
                                                               Best Practices – Recommended fallback                                              recommended actions to support efforts              amend interdealer CSAs
                                                               language should be included for newly                        related protocol
                                                                                                                                                  by market participant to develop clear and          to use and make markets
                                                               issued FRNs, residential ARMs and                                                  effective programs for consumer education and       in SOFR-linked interest
                                                               securitizations                                                                    outreach, as well as for developing materials and   rate volatility products
                                                                                                                                                  information sources to aid for these programs.

                                                                                                                                                  Best Practices – Recommended fallback language should be included for new
                                                                                                                                                  business and student loans; No new applications of LIBOR ARMs; Vendors
                                                                                                                                                  should be ready to support business loans and consumer mortgages; Dealers
                                                                                                                                                  should offer electronic market making in SOFR derivatives
1
 ARRC has published recommended best practices for vendors on completing the transition from LIBOR.
                                                                                                                                                  GSEs to cease issuing new LIBOR-indexed CMOs2
 Fannie Mae and Freddie Mac, the Government Sponsored Entities (GSEs), jointly published a LIBOR Transition Playbook on
2

 their respective LIBOR websites. These websites also include additional key resources focusing on various GSE products.                                                                                                       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                                             Refinitiv                                                      Enhanced
                                       Reuters –                                         transferring                                                      CORRA
                                                                                                                                              Repo
                     CDOR              Refinitiv            No            CORRA           to Bank of      Yes         Yes       Secured                     to be
                                                                                                                                           Transactions
                                      Benchmark                                           Canada in                                                       Published
   Canada                              Services                                              2020                                                         Q2 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

                                                                        Enhanced                                                                          Enhanced
                                   The Association
                                                                       SIBOR to be                                                                          SIBOR
                     SIBOR            of Banks in           Yes
                                                                       published in                                                                       expected
                                   Singapore (ABS)
                                                                       place of RFR                                                                        in 2020

                                                                                                                                            Unsecured
                                                                                                                                             overnight
                                                                                         Monetary                                                         Published
 Singapore                         The Association                                                                                           interbank
                                                                                        Authority of                                                       daily by
                      SOR             of Banks in                          SORA                           Yes         Yes      Unsecured        SGD
                                                                                         Singapore                                                        MAS since
                                   Singapore (ABS)                                                                                         transactions
                                                                                           (MAS)                                                          July 2005
                                                                                                                                            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 Date
Group                    Structure                      RFR Status                  Language Status           Status                    Actions

                         The Cross-Industry             December 2016:                                        Future work plan for      The term reference
                         Committee on Yen Interest      Recommended Tokyo                                     term reference rate       rate is expected to be
                         Rate Benchmarks is divided     Overnight Average Rate                                based on Swaps and        developed throughout
                         into three subgroups and       (TONA) calculated by the                              Futures is discussed      2020 with plans for
                         one working group              Bank of Japan.                                        in the subgroup for       implementation in
 Bank of Japan Study     focusing on:                                                                         the development of        mid-2021.
 Group on Risk-Free                                                                                           term reference rates.
 Reference Rates         1. Loans
                                                                                                              In February 2020,
 Cross-Industry          2. Bonds                                                                            Quick Corp was
 Committee on                                                                                                 selected to prepare
                         3. Development of term
 Japanese Yen Interest                                                                                        for calculating and
                            reference rates
 Rate Benchmarks                                                                                              publishing prototype
                         4. Currency Swaps                                                                   term rates. The
                                                                                                              subgroup considers
                                                                                                              possible timing of the
                                                                                                              implementation is
                                                                                                              around mid-2021.

                         The Euro Working Group         September 2018:             Euro WG “Guiding          On 25 February 2019,      In March 2020, the         There have been 6 issues
                         (WG) currently has four        Recommended €STR to         principles for fallback   the WG published a        WG launched a public       of euro floating rate notes
                         sub-groups, focusing on:       replace EONIA.              provisions in new         summary of responses      consultation on            which reference €STR with
                                                                                    contracts for euro-       to the second public      swaptions impacted by      total volume of €3.85BN.
                         1. Contract robustness        February 2019:
                                                                                    denominated cash          consultation on           the CCP discounting
 Working Group on                                       Euro WG confirms
                         2. Cash products and                                      products” published       determining an €STR-      transition from EONIA
 Euro Risk-Free Rates                                   EURIBOR will continue for
                            derivatives                                             in 2019 to promote        based term structure      to €STR. Based
                                                        the medium term.
                                                                                    effective fallback        methodology as            on the responses
                         3. Financial accounting and
                                                                                    provisions in new         a fallback in euro        received, the WG will
                            risk management
                                                                                    contracts for euro-       interbank offered rate    evaluate potential
                         4. Communication and                                      denominated cash          (EURIBOR) linked          recommendations.
                            education                                               products.                 contracts.
                                                                                                                                        Transition from EONIA to
                                                                                    In 2020, two public       The ECB has               €STR discounting regime
                                                                                    consultations are         announced a call          now due late July 2020.
                                                                                    expected on €STR-         to benchmark
                                                                                    based fallbacks for       administrators for
                                                                                    EURIBOR.                  expressions of interest
                                                                                                              in administering
                                                                                                              an €STR-based
                                                                                                              forward-looking term
                                                                                                              structure.
                                                                                                              The WG may seek
                                                                                                              further input from
                                                                                                              market participants
                                                                                                              through additional
                                                                                                              consultations.

                                                                                                                                                                                                 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 Date
Group                   Structure                      RFR Status                   Language Status           Status                   Actions

                        The WG is broken down into     April 2017:                  In March 2020,            The RFRWG                In January 2020, the WG      There have been 130 issues
                        sub-groups focusing on:        Recommended reformed         the WG published          have confirmed           published its priorities     of sterling floating rate
                                                       Sterling Overnight Index     the results of a          FTSE Russell,            and milestones for 2020.     notes which reference
                        1. Bonds
                                                       Average (SONIA).             consultation on credit    ICE Benchmark                                         SONIA with total volume of
                                                                                                                                       In March and April
Bank of England         2. Loans                                                   adjustment spread         Administration,                                       £60.2BN, this is in addition
                                                                                                                                       2020, the WG issued
Working Group on                                                                    methodologies for         Refinitiv and HIS                                     to 44 securitisation deals
                        3. Communications                                                                                             statements regarding
Sterling Risk-Free                                                                  fallbacks in cash         Markit are working                                    referencing SONIA with total
                           & Outreach                                                                                                  the impact of COVID-19
Rates (RFRWG)                                                                       products.                 on development                                        volume £26.6BN.
                                                                                                                                       on the timeline for firms’
                        4. Pension Funds &                                                                   of a Term SONIA
                                                                                    The WG also                                        transition plans including   There is now numerous
                           Insurance Companies                                                                Reference Rate.
                                                                                    established a Tough                                impacts to the 2020          originations of SONIA-
                        5. Infrastructure                                          Legacy Task Force to      In January 2020, the     objectives.                  referenced loans in the
                                                                                    provide market input      WG published “Use                                     sterling market, after the
                        6. Term Rates (Task Force)
                                                                                    regarding products        Cases of Benchmark                                    market opened in July 2019.
                        7. Accounting/Tax (Task                                    that may prove unable     Rates: Compounded
                            Force)                                                  to be converted or        in Arrears, Term
                        8. R
                            egulatory Dependencies                                 amended to include        Rate and Further
                           (Task Force)                                             robust fallbacks.         Alternatives.”

                        The WG is broken down into     June 2017: Recommended       ARRC agreed on            ARRC’s Paced             In April 2020, the           There have been 735
                        sub-groups focusing on:        Secured Overnight            principles for fallback   Transition Plan          WG published its key         issuances for a combined
                                                       Financing Rate (SOFR)        language, published       sets Q2 2021 goal        objectives and milestones    total amount of USD
                        1. Accounting/Tax
                                                       as the RFR to replace U.S.   late Sept 2018.           to create “a term        for 2020.                    736.72BN.
Alternative Reference   2. Business Loans             dollar LIBOR.                                          reference rate based
                                                                                    To date, the ARRC
Rates Committee                                                                                               on SOFR derivatives
                        3. Consumer Products           April 2018: New York         has released
(ARRC)                                                                                                        markets once liquidity
                                                       Federal Reserve              recommended
                        4. Floating Rate Notes                                                               has developed
                                                       Bank (NYFRB) began           fallback contract
                                                                                                              sufficiently to
                        5. Legal                      publication of SOFR.         language for ARMs,
                                                                                                              produce a robust rate.
                                                                                    bilateral business
                        6. Market Structure and
                                                                                    loans, FRNs,              The FRB published
                           Paced Transition
                                                                                    securitizations and       various sets of data
                        7. Operations/Infrastructure                                syndicated loans.         on indicative forward-
                        8. Outreach/                                               In March 2020, a          looking SOFR term
                           Communications                                           consultation was also     rate data (last update
                                                                                    released relating to      April 2019)
                        9. Regulatory Issues                                       variable rate private
                        10. Securitizations                                        student loans.

                        11. Term Rates                                              In March 2020, the
                                                                                    ARRC published
                                                                                    responses to a
                                                                                    consultation on
                                                                                    “Spread Adjustment
                                                                                    Methodologies for
                                                                                    Fallbacks in Cash
                                                                                    Products Referencing
                                                                                    USD LIBOR.”

                                                                                                                                                                                                   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 Date
Group                  Structure                       RFR Status                   Language Status           Status                  Actions

                       The WG is broken down into      October 2017:                May 2020:                 WG has                  Publication of a cross      The first SARON-linked
                       sub-groups focusing on:         Recommended Swiss            The NWG discussed         recommended using       currency basis swap         public issuance was in
                                                       Overnight Average Rate       LIBOR end-scenarios       compounded SARON        (CCBS) term sheet           August 2019 with Credit
                       1. Derivatives & Capital
                                                       (SARON).                     and fallback              wherever possible       and updated cap             Agricole issuing CHF 525
                          Markets
                                                                                    language. The NWG                                 (floor) term sheet were     mm in perpetual tier 1 notes.
National Working       2. Loan and Deposit Markets                                 recommended “to use                               identified as next steps
Group on Swiss Franc                                                                                                                                              In April / May 2020, multiple
                                                                                    the lookback method                               following the May 2020
Reference Rates                                                                                                                                                   Swiss retail banks began
                                                                                    for CHF syndicated                                NWG meeting.
                                                                                                                                                                  offering SARON-linked
                                                                                    loans with an offset of
                                                                                                                                                                  residential mortgage loans.
                                                                                    5 business days.”

                       RBA recognizes three            BBSW has been                                          BBSW has been           RBA and relevant            There have been three
                       working groups related to       strengthened and will                                  strengthened and        regulators will continue    issuances for a combined
                       interest rate benchmark         continue to be published                               will continue to be     to monitor both BBSW        total amount of AUD 1.41BN.
                       reform.                         going forward.                                         published.              and AONIA.
Reserve Bank of
                       1. ASX BBSW Advisory           AONIA is being published                               RBA evaluated that
Australia Interest
                          Committee focuses on         as an RFR as part of a                                 there are enough
Rate Benchmark
                          BBSW Benchmark               “multiple rates” approach.                             transactions to
Reform Page
                                                                                                              determine BBSW and
                       2. Australian Financial
                                                                                                              that it will continue
                          Markets Association
                                                                                                              to exist as part of a
                          (AFMA) focuses on
                                                                                                              multi-rates approach.
                          promoting industry
                          dialogue and information
                          sharing
                       3. Australian Securitisation
                          Forum (ASF) established
                          a working group to
                          consider benchmark
                          reform on the Australian
                          Securitisation Market

                       The Canadian Alternative        CARR endorses an             CARR developed            CDOR will continue      Fallback language will
                       Reference Rate Working          enhanced CORRA based         Principles for            to exist as a part      be finalized after ISDA
                       Group (CARR) is sponsored       on the recommendations       Enhancements to           of a multiple rates     finishes its consultation
                       by the Canadian Fixed-          outlined in their            Fallback Language.        approach.               on fallback language for
                       Income Forum (CFIF)             consultation paper with                                                        CDOR and other rates.
Canadian Alternative   which is a group set up by      no changes based on
Reference Rate                                                                                                                        CARR and CFIF will
                       the Bank of Canada. Both        responses.
Working Group                                                                                                                         monitor and review issues
                       groups are comprised
                                                       CFIF endorses                                                                  for transition from CORRA
                       of market participants
                                                       monitoring and reviewing                                                       to an enhanced CORRA.
                       and Bank of Canada
                                                       issues for transition by
                       representatives.
                                                       the transition subgroup
                                                       and by the benchmark
                                                       admin.

                                                                                                                                                                                                  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 Date
Group                   Structure                     RFR Status                   Language Status   Status                   Actions

                        As HONIA’s administrator,     The WGARR has                                  HIBOR will continue      Technical adjustments
                        the TMA established an        proposed technical                             to exist as a part       may be made to HONIA
                        internal Working Group on     refinements to HONIA                           of a multiple rates      based upon industry
                        Alternative Reference Rates   outlined in an April 2019                      approach.                feedback to the
                        (WGARR).                      consultation paper.                                                     consultation paper.
                                                                                                     TMA may also try to
Hong Kong Treasury
                                                      Refinements relate to                          develop an OIS curve     There are no plans to
Markets Association
                                                      the rate’s data source,                        for HONIA depending      discontinue HIBOR and a
Working Group on
                                                      reporting window and                           on market conditions     multi rate approach will
Alternative Reference
                                                      publication time.                              and demand.              be adopted using both
Rates “WGARR”
                                                                                                                              HONIA and HIBOR.
                                                      In December 2019, TMA
                                                      and WGARR published                                                     Fallback language will
                                                      the conclusion of the                                                   be developed after ISDA
                                                      April 2019 consultation                                                 finishes its consultation
                                                      paper.                                                                  on fallback language for
                                                                                                                              HIBOR and other rates.

                        SC-STS was established        The ABS Benchmarks Co                          SIBOR will continue to   Enhanced SIBOR is           The first DBS bond tied
                        by the Monetary Authority     Pte td and the Singapore                       be published.            expected to go through      to SORA was issued on 14
                        of Singapore (MAS) with       Foreign Exchange Market                                                 testing and transition      May 2020.
                                                                                                     An enhanced SIBOR
                        the Association of Banks in   Committee (ABS-SFEMC)                                                   in 2020.
                                                                                                     is expected to
                        Singapore (ABS) providing     have worked together to
                                                                                                     be implemented           SC-STS published a
Steering Committee      administrative support.       develop a proposal to
                                                                                                     in 2020. ABS-            transition roadmap for
for SOR Transition to   SC-STS has four subgroups     strengthen SIBOR.
                                                                                                     SFEMC published          SOR to SORA highlighting
SORA (SC-STS)           focusing on:
                                                      ABS-SFEMC has also                             a consultation and       key priorities and
                        1. Derivatives                identified SORA as the                         announcements            milestones.
                                                      alternative reference rate                     regarding the
                        2. Bonds / Perpetual
                                                      for SOR.                                       development of these
                           Securities
                                                                                                     enhancements.
                        3. B
                            usiness / Syndicated
                           Loans
                        4. Consumer Products

                                                                                                                                                                                     9
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