LIBOR Transition:  FCA Announcement on Final Publication Dates

On 29 September, the Financial Conduct Authority (“FCA”) made an announcement and provided an update on the final publication dates for currently published LIBOR tenors. For persons managing contracts that have yet to transition from LIBOR to an alternative, this provides some important clarity on the time remaining to complete that transition.

The FCA announcement (here), which takes into account feedback to an earlier consultation, outlines the following:

  • Sterling:  publication of 1- and 6-month synthetic LIBOR will receive a final extension until 31 March 2023 (the previous end-date had been 31 December 2022).  The FCA states “…these settings will permanently cease immediately after final publication on 31 March 2023”.  With regard to 3-month synthetic LIBOR, the FCA is still considering responses received to its consultation (including suggestions that the 3-month tenor should be published for a further limited period beyond 31 March 2023) and will provide further information in due course.
  • Yen:  for synthetic yen LIBOR, there will be no extension to the previously announced end-date and publication will cease permanently on 31 December 2022.
  • Dollar:  unlike sterling and yen, US dollar LIBOR continues to be published on a non-synthetic basis with publication currently scheduled to end on 30 June 2023.  The FCA notes that it is assessing feedback in relation to the possibility of requiring publication of US dollar LIBOR, using a synthetic methodology, for a limited additional period.  An update on the FCA’s intentions is expected later in Autumn 2022.

The FCA announcement is a timely reminder of the importance of transitioning from LIBOR to alternative rates, especially if existing LIBOR-based contracts do not include effective fallback provisions.  We will continue to monitor publications from the FCA and provide further briefings on important developments as they arise.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.