Reform at a Glance
As financial markets transition away from using LIBOR to an alternative, banks and their clients will make a coordinated effort for the transition to happen smoothly. Below is a brief guide.
EURIBOR: can continue to be used as a benchmark under BMR rules
The Euro Interbank Offered Rate (EURIBOR) is an unsecured market benchmark rate calculated by a panel of selected banks, and administrated and published by the European Money Markets Institute (EMMI) for several maturities (one week, and one, three, six and twelve months).
In order to satisfy the requirements of the European Benchmark Regulation, EMMI has developed a new calculation methodology (so called “Hybrid Methodology”). Under the new Hybrid Methodology, EURIBOR is calculated using real transactions whenever such transactions are available.
From EONIA to €STR
EONIA in its previous form could become non-compliant with the EU BMR, given the scarcity of underlying transactions and high concentration of volumes among a small number of contributors.
In order to maintain EONIA for a transitional period and until its discontinuation on January 3rd 2022, its methodology has been changed and, since October 2nd 2019, EONIA has been computed as €STR plus a fixed spread of 8.5 basis points. The €STR reflects the wholesale euro unsecured overnight borrowing costs of euro area banks and is based exclusively on real transactions reported to the ECB.
EONIA will be published for the last time on January 3rd 2022 and discontinued thereafter; all contracts maturing after this date and referring to EONIA must have a written fallback clause providing for its substitution.
From London Interbank Offered Rate (LIBOR) to Alternative Reference Rate (ARR)
LIBOR, the London Interbank Offered Rate, is currently produced centrally in London by ICE Benchmark Administrator in seven tenors (or lengths), from overnight up to 12 months, for 4 currencies (see the table below) and the UK’s Prudential Regulation Authority (PRA) is responsible for its regulation.
The Financial Conduct Authority (FCA) has made it clear that the publication of LIBOR is not guaranteed beyond 2021 and thus firms must transition the existing contracts to Alternative Reference Rates before this date (ARRs).
ARRs are overnight nearly risk-free reference rates, which have been identified as alternative benchmarks for the existing key interbank offered rates (IBORs). Such rates are robust and are anchored in active, liquid underlying markets.
A selection of possible alternatives to LIBOR around the world:
LIBORs
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ARRs
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LIBOR USD
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SOFR, Secured overnight financing rate (Secured Transactions)
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LIBOR GBP
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SONIA, Sterling overnight index average (Unsecured Transactions)
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LIBOR JPY
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TONAR, Tokyo overnight average (Unsecured Transactions)
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LIBOR CHF
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SARON, Swiss average rate overnight (Secured Transactions)
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Fallback Provisions
To address the risk that one or more LIBORs or benchmarks are discontinued while market participants continue to have exposure to that rate, financial institutions and clients are encouraged to agree to contractual fallback provisions using ARRs as replacement rates.
The fallback rates are being developed to ensure contracts’ continuity once LIBOR is discontinued. Furthermore, market participants must ensure that the contracts align as closely as possible to the original agreement after the fallback kicks in, resulting in a rate that is predictable, transparent and fair.
Work is underway across numerous jurisdictions to develop contractual fallbacks in order to mitigate the risk associated with the uncertainty of LIBOR’s existence post-2021 and therefore to reduce potential uncertainties if it ceases to be used.