Learnings from the LIBOR "Dear CEO" letter

On Wednesday 5 June, the Financial Conduct Authority (FCA) and the Bank of England held the conference ?Last orders - Calling Time on LIBOR?. The event provided the industry with an update of the regulators? perspective on the transition from LIBOR to alternative risk-free rates (RFRs), and also provided feedback from the ?Dear CEO?, on which UK Finance submitted a letter to the authorities.

The messages from the regulators were clear. Top of the list is that there are no plans for LIBOR to continue after the stated cessation date of the end of 2021 - all industry participants should be working towards that date.

The need for the authorities (primarily through the Bank of England RFR WG and its various sub-working groups) and the industry to work together remains paramount. There was also significant emphasis on the need for institutions to ensure they had sufficient buy-in from senior management.

The findings from the ?Dear CEO? exercise should be of significant value to all stakeholders implementing transition plans. Assessments should be proportionate to the nature, scale and complexity of LIBOR exposure.

Once firms have identified their exposure, the associated risks (such as prudential and conduct) and how they could play out in various scenarios should be considered with the appropriate level of granularity. Again, there was emphasis on the need for clear and appropriate governance with sufficient support from senior management.

Although the ?Dear CEO? letter was addressed to major banks and insurers, the findings and the lessons learned from the exercise can certainly be applied to all stakeholders with contracts of products linked to LIBOR, and it is worth reading in full.

UK Finance is very supportive of the industry efforts to transition away from LIBOR, and we are leading on the critical product areas of mortgages and commercial loans. Both of these have considerable exposure to LIBOR and will inevitably require the consideration of a variety of regulatory, legal, and conduct risks to be overcome.

We are also very supportive of the excellent work our fellow trade associations are undertaking across the various product lines and would like to commend the regulators for the support they are giving to the industry in this transition process.

In the context of LIBOR, the end of 2021 is not as far away as it sounds - please do take heed of the messages coming out of the event, and do not hesitate to contact us if we can assist your transition efforts in any way.