To our clients and friends:
The Board of Governors of the Federal Reserve System has proposed regulations to implement the Adjustable Interest Rate Act (the “LIBOR Act”). The LIBOR Act and the Federal Reserve’s proposed implementing regulations are intended to address the discontinuation of the USD LIBOR benchmarks on June 30, 2023, by establishing a SOFR-based replacement benchmark that will automatically apply to agreements that rely on LIBOR and do not have a contractual non-LIBOR-based fallback benchmark.
Our newsletter, which summarizes the key provisions of the proposed regulations, is available here.