Welcome to the latest issue of Mayer Brown’s IBOR Transition Digest—a periodic compendium of global regulatory and market developments and insights on the complex issues confronting financial market participants as they plan to transition from LIBOR and its variants to replacement benchmark interest rates. As attention to IBORtransition accelerates and becomes more focused, it is critical to have access to comprehensive and timely resources about the market.

For additional resources and an introduction to our global cross-practice IBOR Transition Task Force, please visit Mayer Brown’s IBOR Transition portal.

Thought LeadershipNews and Developments | Events



United States – General

Revised Supervision and Regulation Letter SR21-12: Answers to Frequently Asked Questions on the Transition Away from London Interbank Offered Rate (LIBOR)
Board of Governors of the Federal Reserve System, 19 November 2021
The Fed’s frequently asked questions (FAQs) to assist supervised firms in the transition away from using the LIBOR as a reference rate have been revised. The supervisory letter includes both the original July 2021 FAQs, as well as the revised November 2021 FAQs. The revised FAQs focus on defining “new contracts,” the continuing use of fallback provisions, and supervisory focus with respect to LIBOR transition.

Canada - General

CARR publishes CORRA-related recommendations and key findings in its review of CDOR

Canadian Alternative Reference Rate Working Group, 23 November 2021
The Canadian working group published a suite of resources to facilitate the transition to the Canadian Overnight Repo Rate Average, including conventions for Floating Rate Notes, conventions for CORRA-referencing loans (including an example calculation and a comparison to conventions in other jurisdictions), fallback language for CORRA-referencing FRNs, and an update on the analysis of CDOR as the primary interest rate benchmark in Canada.


Europe – General

Final Report on draft RTS on the clearing and derivative trading obligations in view of the benchmark transition to risk free rates
European Securities and Markets Authority, 18 November 2021
Presenting draft regulatory technical standards that amend the scope of existing RTS relating to clearing and derivative trading obligations to transition away from EONIA and LIBOR to risk free rates. The report reflects responses to ESMA’s related July 2021 consultation.

Asia & Pacific Rim – General

Final Report on the Results of the Public Consultation on the Treatment of Tough Legacy Contracts in Japan
Bank of Japan, 19 November 2021
Summarizing the responses to its related September 2021 consultation and providing guidance on the legacy contracts that could consider using synthetic JPY LIBOR and issues to be considered in using synthetic JPY LIBOR.

Update to the SORA Market Compendium: Transition from SOR to SORA
Steering Committee for SOR & SIBOR Transition to SORA, 17 November 2021
Providing an update regarding the current use of SOR by financial product and application of SORA as a replacement in light of the developments in IBOR transition during 2021.



Replays of all of our IBOR Transition Webinar Series presentations are available via iTunes podcasts, Google play or Spotify, as well as on the IBOR Transition Webinar Series page of our dedicated IBOR Transition portal.

LIBOR Transition: How Will the Pieces Come Together in Time
ABA Webinar, 9 December 2021
Paul Forrester and Matt Bisanz will speak on how they see IBOR transition progressing through 2022 and what market participants need to know.

The Derivatives Market
Webinar, 15 November 2021
Ed Parker provides an overview of IBOR developments in the UK derivatives market.

The U.S. Derivatives Market
Webinar, 11 November 2021
Anna Pinedo provides an overview of IBOR developments in the U.S. derivatives market.

Where Are We Now & Where Are We Going? The Transition Away From IBORs
Webinar, 10 November 2021
Ed Parker and David Duffee provide a recap of the status of IBOR transition in the loan and derivative markets.

Antitrust Considerations for IBOR Transition
Webinar, 4 November 2021
Britt Miller and Tom Panoff discuss antitrust conduct risk related to the IBOR transition process.

Requirements of Regulators Around the World – UK, EU, Asia, and US
Webinar, 30 September 2021
Comparing regional regulatory regimes and the status of legislation to facilitate IBOR transition.

IBOR Transition – an introduction to conduct risk
Webinar, 16 September 2021
Mayer Brown partner Marlon Paz, and head of Legal Project Management David George, discusses IBOR transition conduct risk and related risk mitigation in the first of our latest IBOR transition webinar series. With approximately 100 days until most LIBOR tenors cease to be published, additional topics to be covered during 4Q2021 include global transition regulatory requirements, industry- and subject matter-specific considerations, litigation risks, and final transition preparation tips.