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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