The London Interbank Offered Rate (LIBOR) is a measure of ... submitting to LIBOR, but only until 2021. News release. Executive Summary This may require an amendment to any existing terms and conditions which may in … The transition from LIBOR is important because the potential disruption or cessation of LIBOR poses a financial stability risk as well as a risk to the individual firms with LIBOR exposures. Although its origins date back to 1969, it was not formalized until the British Bankers' Association began overseeing the collection and governance of the data nearly 2 decades ... the London Interbank Offered Rate (LIBOR) has been one of the most widely used interest rate benchmarks in the world. IBA consulted on the issue of LIBOR publication cessation because “a majority of LIBOR panel banks had communicated to IBA that they would […] It could be very helpful for loans if the time is used thoughtfully . Borrowers, including businesses and consumers, who have current loan products referencing LIBOR may be affected by this transition. On April 6, 2021, New York Governor Mario Cuomo signed into law legislation tackling the uncertainties surrounding the LIBOR transition, particularly for legacy contracts.. The LIBOR transition is an ongoing issue that we are closely monitoring. The FCA also stated it will consult in Q2 2021 on the publication of certain LIBOR settings on a ‘synthetic’ basis (a different calculation methodology) after the aforementioned dates to potentially support the transition of ‘tough legacy’ contracts (contracts that are expected to be particularly difficult to transition… facilitate the transition from US Dollar LIBOR-based floating rates to SOFR-based floating rates. ... the London Interbank Offered Rate (LIBOR) has been one of the most widely used interest rate benchmarks in the world. The end of LIBOR has been referred to by some pundits as the financial market equivalent of Y2K—the time-boxed tech scare that assumed the world’s computers would shut down as 1999 turned to 2000—but the transition is meant to be gradual and measured. The Publication of 26 LIBOR settings will permanently cease immediately … Sometime after 2021, LIBOR is expected to be discontinued. A number of important LIBOR transition-related announcements were released on March 5, 2021, by the UK Financial Conduct Authority (FCA) and approved by the Alternative Reference Rates Committee (ARRC), relating to confirmation of the cessation dates for LIBOR and spread adjustments. FCA has confirmed all Libor settings will cease immediately on 31 December for major currencies as firms are urged to complete transition plans. The global financial industry is preparing to transition away from a key benchmark interest rate — the London Interbank Offered Rate, or LIBOR — to new alternative rates. Fitch Ratings-Singapore-24 January 2021: The transition of Japanese yen (JPY) London interbank offered rates (Libor) to new benchmark rates risks falling behind the end-2021 deadline at the current pace of progress, which could delay the transition for legacy cash products and have an impact on interbank rate volatility. End of LIBOR: What you need to know Webinar. It is possible that LIBORs may be deemed to be unrepresentative prior to these dates. What is the LIBOR transition timeline? The historical median approach involves comparing the relevant LIBOR and compounded risk free rate for an equivalent tenor over a significant static look back period of five years prior to the date of transition. The announcement constitutes an index cessation event under the IBOR Fallbacks Supplement and the ISDA 2020 IBOR Fallbacks Protocol for all 35 LIBOR settings. U.S. regs urge banks to transition from LIBOR ‘as soon as practicable’ 2020-11-30T19:17:00Z. The transition to alternative reference rates will demand focus and coordination across the organization. What's new: LIBOR has a definitive end date. b) Determine the transition date for existing indices and the cutoff date when new index launches can no longer use affected IBORs S&P DJI continues to monitor market developments around the LIBOR transition to determine the transition date for existing indices and cutoff date for new indices to cease utilizing affected IBORs. Stay up to date as the banking world changes to a new index benchmark. 30+ days ago Save job Not interested Report job Background and Current State of the Transition The impending phase-out of the London Interbank Offered Rate (LIBOR) by December 31, 2021, has become a key issue facing financial markets, as it is one of the most widely used reference rates, with nearly $200 trillion of derivatives, loans, and securities referencing USD LIBOR (according to the Second Report of the ARRC). LIBOR Crosses the Pond, Banking New York, October 1, 2012; For private plaintiffs, all eyes on possible UBS deal, The National Law Journal, December 14, 2012 Document citation 85 FR 36938. Information in the LIBOR Transition Playbook is preliminary and subject to revision and updates from time to time. The transition to ARR may require renegotiating the spread due to the differences between LIBOR and ARR, such as credit and term premiums. However, under either approach, the loan document may permit the agent and the borrower to elect an earlier transition date under an “early opt-in” trigger. The NCUA issued new guidance today to federally insured credit unions on the London Inter-bank Offered Rate (LIBOR) transition. The UK’s Rush to End LIBOR Use • To speed up the transition away from LIBOR, the Sterling Working Group has suggested a replacement rate choice for loans or, alternatively, a mechanism which would allow lenders/borrowers to move away from LIBOR before the official cessation date. Despite the significant transition efforts to date, LIBOR is still the dominant benchmark in new global contracts. As we move closer to the transition date, all contracts which will continue after LIBOR cessation will need to be renegotiated and replaced,” it said. First is the trigger event that initiates the transition from LIBOR to a replacement rate. The dates 31 December 2021 and 30 June 2023 loom large in the marathon race to consign the tainted LIBOR benchmark rates to history. This issue touches numerous parts of the economy. This article examines where we are now in the transition including the implications of the recent FCA announcement regarding LIBOR cessation for existing LIBOR-based transactions as well as exploring what end of Q1 2021 deadline means in practice for future … Fannie Mae highlights the achievement of key milestones, as it continues advancing the mortgage market's readiness for the anticipated future cessation of LIBOR. The Mortgage Bankers Association (MBA) recently released templates, one in a notice form and one in letter form, to advise borrowers with existing adjustable rate mortgage (ARM) loans that use the London Interbank Offered Rate (LIBOR) as the index of the upcoming transition away from LIBOR. The transition away from the London Interbank Offered Rate (LIBOR) has been in the works for many years, but a clear endgame for LIBOR has now been established. The statements intend toallow enough time to address a significant proportion of legacy contracts that reference USD LIBOR as well asprovide a clear end date for issuances of new USD LIBOR contracts. This briefing discusses benchmark transition challenges related to LIBOR-based floating rate notes and securitizations and related issues to be U.S. banking regulators are encouraging financial institutions to stop entering into new contracts that use the U.S. dollar LIBOR as a reference rate … The year-end date should be seen as binding. LIBOR Currency: LIBOR Tenors: Final Date of Representativeness: Potential for Non-Representative, Synthetic Publication ... LIBOR Transition Overview. US Banking Agencies have said that banks should stop originating LIBOR contracts as soon as practicable, but in any event, no later than 12.31.21. Creating and managing project teams. The bottom line is that for USD LIBOR, the one-day, one-month, six-month and one-year LIBOR rates will cease publication in June 2023. For a detailed analysis of the ARRC’s objectives, see our previous report: ARRC Announces Its 2020 Objectives for Transition Away from USD LIBOR, April 24, 2020. Learn more Update on Multifamily’s Transition to SOFR-indexed ARMs . 10 misconceptions about LIBOR transition and avoiding setbacks. To facilitate the transition of loans from LIBOR to SOFR, in May 2019, the ARRC developed LIBOR fallback language to help promote market consistency for the transition process. At this stage in the transition away from LIBOR, we note that companies most frequently providing LIBOR transition disclosure are in the real estate, banking, and insurance industries. On March 5, 2021, the IBA announced that one week and two month US LIBOR rate quotes will cease at the end of 2021, and that all remaining US LIBOR rate quotes will cease at the end of June, 2023. After the Protocol Effective Date, the $500 fee will apply to all. The agency encourages all federally insured credit unions to transition away from using the U.S. dollar LIBOR settings as soon as possible, but no later than December 31, 2021. FCA finally announces Libor transition end date. 5 March 2021 is therefore the date on which the fallback spread adjustment will be fixed. And despite the significant impact of COVID-19 on the industry, the LIBOR transition to SOFR is still set for the end of 2021 as scheduled. Transition away from LIBOR by end-2021 requires significant commitment and sustained effort from both financial and non-financial institutions across many LIBOR and non-LIBOR jurisdictions. It is expected that active USD LIBOR rates will cease publication after June 30, 2023 (the “USD LIBOR Transition Date”). The London Interbank Offered Rate (LIBOR) is a global benchmark interest rate calculated daily, and is the most widely used benchmark in the capital markets. Banking regulators are focusing on the LIBOR transition as well; in the Semiannual Risk Perspective for Fall 2019, the Office of the Comptroller of the Currency (OCC) highlighted the 2021 end date for LIBOR and noted that “the OCC is increasing regulatory oversight of this area to evaluate bank awareness and preparedness.” Paul Hastings and Lexology co-hosted a webinar focused on key aspects of the Libor transition and what market participants need to consider as they evaluate industry developments, best practices and market trends and plan for and implement their firm-wide Libor transition programs. Find out more about ongoing transition initiatives and actions the FCA is taking to facilitate the transition. The key to maintaining transition momentum is moving primary market activity away from dollar Libor. Following the 5… 2 1.1 Session Objectives 1. Freddie Mac is working closely with the Federal Housing Finance Agency and other industry participants on a thoughtful and deliberate process to replace or end the use of certain established reference rates, such as LIBOR, COFI and CMT, in its products, issuances and contracts. Unfortunately this position has been closed but you can search our 51 open jobs by clicking here. Key Industry Participants The transition from LIBOR to more robust reference rates is driven by key industry participants around the world. The interest rate benchmark LIBOR is expected to cease after end-2021. Stay up to date on the latest developments, key dates, and how M&T is preparing for the transition. ASIC (Australian Securities and Investments Commission) has warned against a passive approach to LIBOR transition, and for regulated firms to make sure they mitigate possible conduct risks. Here's what you need to know. Transcript Edited for clarity [Ken Bentsen] Thank you for joining us for this episode in SIFMA’s podcast series.I’m Ken Bentsen, SIFMA’s president and CEO. LIBOR Transition Overview. 1.2 Key outcomes Our clients are aware of the important elements and considerations in their transition planning. The trigger for the automatic transition will occur on the dates upon which the relevant LIBOR settings are no longer published or the dates upon which the relevant LIBOR settings are no longer representative. Setting targets, timelines, and budgets. The industry continues to prepare for the transition away from IBORs, while the end date for certain USD LIBOR tenors is likely to be postponed until 2023. Regulators have called for a market-wide transition away from LIBOR by the end of 2021. LIBOR Transition. Background. Delaying dollar Libor cessation reduces the number of affected contracts as most will mature before end-June 2023. 2021: LIBOR Transition, the alternative RFRs for each of the five LIBOR currencies have now been identified. Questions around the viability of LIBOR first arose from the LIBOR manipulation scandals that came to light beginning in 2007, though allegations of manipulation date back to the 1990s. In the NPRM, the Bureau is proposing examples of replacement indices for LIBOR for open-end products that meet Regulation Z standards. On 5 March 2021, ICE Benchmark Administration (“IBA”), the administrator of LIBOR, released the much anticipated feedback statement (“Cessation Statement”) reporting the results of its 4 December 2020 Consultation on Potential Cessation. That is the final publication date for international LIBORs (GBP, EUR, CHF, JPY) as well as the 1-Week and 2-Month USD LIBOR … Fannie Mae, Freddie Mac, and the Federal Home Loan Banks (FHLBanks) all have financial instruments that reference Intercontinental Exchange London Interbank Offered Rate (ICE LIBOR) , the most widely used interest rate benchmark in the world.. On Tuesday, March 9, 2021, the New York State Senate’s Judiciary Committee unanimously approved Senate Bill S. 297A for consideration on the Senate floor. But with LIBOR based on a dwindling number of interbank transactions, it will be replaced by the Secured Overnight Financing Rate (SOFR) for derivatives and likely for syndicated loans as well. We invite you to discover previously published media commentary and client alerts by Les Jacobowitz concerning the LIBOR-SOFR transition below. In brief The IBA is consulting on a proposed extension of certain USD LIBOR tenors until June 2023. This document is an indicative summary of our preliminary analysis regarding the potential upcoming LIBOR transition. A broad indicator of trading activity across derivatives markets in the 5 LIBOR currencies (plus the Australian dollar) shows increasing adoption of RFRs, but it remains at a low level (Graph A.1). The transition away from LIBOR dates back to the aftermath of the financial crisis and the discovery of a widespread rate-rigging scandal that resulted in fines amounting to over US$9bn. Acquisitions of single-family and multifamily LIBOR ARMs will cease on or before December 31, 2020. The effective annual interest rate you pay based on the new index and margin should be “substantially similar” to the rate you pay based on the LIBOR index and the applicable margin, using the two index values as of Dec. 31, 2020, rather than the date on which LIBOR becomes unavailable. On March 24, the New York State Legislature passed Senate Bill 297B/Assembly Bill 164B (“Bill”) [1] which addresses the legal uncertainty and potential adverse impacts associated with the transition away from the London Interbank Offered Rate (“LIBOR”) due to its upcoming cessation. Unofficial Redline. However, on 5 March 2021, the UK Financial Conduct Authority (FCA) finally announced the dates by which panel banks’ submissions for any LIBOR will stop and LIBOR will no longer be representative. Basics of transition Who are the key players in the LIBOR transition? Banks and financial markets are preparing for the imminent end of the London Interbank Offered Rate (LIBOR), the most widely used benchmark for short-term interest rates. The first is December 31, 2021. This letter provides guidance on the discontinuance of the London Inter-Bank Offered Rate (LIBOR) that will assist examiners’ assessment of a credit union’s preparations in transitioning away from LIBOR to an alternative reference rate or rates. LIBOR Transition updates provide the latest news on global benchmark change Stay up to date on the transition from LIBOR to alternative reference rates, including SOFR, SONIA, SARON, €STR and TONA. This information is intended to inform East West Bank customers on the industry transition from LIBOR to an alternative benchmark interest rate. Key skills in demand include Payments (incl. In July 2017, the Financial Conduct Authority (FCA) announced that the availability and reliability of the London Interbank Offered Rate (LIBOR) beyond 2021 would not be guaranteed. Keep up to date with some of the latest news and announcements from key industry bodies around the world on the LIBOR transition. Instead, the transition to (SOFR) will automatically occur upon the Cessation Dates of the relevant LIBOR settings. On 5 March 2021, ICE Benchmark Administration ("IBA"), the administrator of LIBOR, released the much anticipated feedback statement ("Cessation Statement") reporting the results of its 4 December 2020 Consultation on Potential Cessation.IBA consulted on the issue of LIBOR publication cessation because "a majority of LIBOR panel banks had communicated to IBA that they would not be … Used globally, LIBOR is often referenced in derivative, bond and loan documentation, and in a range of consumer lending instruments such as mortgages and student loans. Our semi-monthly update features PwC’s take on the adoption of the new risk-free reference rates, a summary of industry publications, and key transition milestones. ... or would like assistance with, the LIBOR transition. The Alternative Reference Rates Committee (ARRC) has released the “Progress Report: The Transition from U.S. Dollar (USD) LIBOR,” outlining key reference rate reform efforts, progress to date, and areas requiring further work. When asked where they were in the LIBOR transition process, 34% of financial institutions stated that they were on track to be ready by the end of 2021, while 14% said that they would not be ready until at least Q1 2022. These announcements ease a good amount of transition … Libor is phasing out and may cease to exist past 2021. The year 2020 is a critical year for preparing for LIBOR cessation. In December 2020, we produced an article on the transition of the London Inter-bank Offered Rate (LIBOR) to alternative risk free rates (RFRs). In any event, the parties could use the early opt-in election to transition from LIBOR to an alternative benchmark rate. On March 5, 2021, regulators and industry groups provided market participants with much anticipated clarity by announcing the dates for the cessation of publication of, and non-representativeness of, various settings of the London Interbank Offered Rate which will allow market participants to identify the date that their financial instruments and commercial agreements that reference LIBOR … Holland & Knight's Libor Transition Team advises clients across the full spectrum of industries, businesses and jurisdictions, providing multi-disciplinary guidance on all aspects of the London Interbank Offered Rate transition, including tax implications, regulatory compliance, dispute resolution and litigation. As a result, British regulators have announced that LIBOR will be discontinued between December 31, 2021, and June 30, 2023. Due to various scandals involving LIBOR manipulation, the Financial Conduct Authority (FCA), which regulates LIBOR, announced in July 2017 that banks would no longer be required to submit information for the calculation of LIBOR after December 31, 2021, effectively discontinuing LIBOR as of that date ( “Cessation Date”). EONIA is expected to be discontinued on 3 January 2022. [7] ARRC 2020 Objectives for LIBOR Transition, April 17, 2020. Only 14 percent of post-cessation date loans have robust fallbacks in place, said ASIC’s Nathan Bourne at a Bloomberg-ICMA webinar. Scoping LIBOR transition across institutional functions. booked at closing curve levels ($0 NPV) as of the transition date. What you’ll need: Citizenship: You are a citizen of one of our 48-member countries. By Jennifer J. Kafcas, Alvino S. van Schalkwyk, Lauren J. Blaber & Harry Poland on March 5, 2021. There has been a lot of progress made to date in the transition away from Libor. On­­­­ April 6, 2021, New York Governor Andrew Cuomo signed into law the LIBOR transition bill (Senate Bill 297B/Assembly Bill 164B) promoted by … If institutional loans refinance three years after origination, then half of outstanding loans could transition into SOFR before LIBOR ceases – considerably reducing remediation pressures. The transition to ARR may require renegotiating the spread due to the differences between LIBOR and ARR, such as credit and term premiums. The dates 31 December 2021 and 30 June 2023 loom large in the marathon race to consign the tainted LIBOR benchmark rates to history. Introduction It’s long been clear that LIBOR can’t be relied upon after the end of 2021, but today’s announcement by the UK Financial Conduct Authority (FCA) on LIBOR’s future will likely put a rocket on transition efforts. CFPB issue date JUN 04, 2020. Since end-2020 (post-Transition), the PRA has been required to publish technical information (TI) that includes the risk-free rates for each currency. This is an important step towards the end of LIBOR, and the Bank of England and FCA urge market participants to continue to take the necessary action to ensure they are ready. 2020 LIBOR Transition Milestones. Fast Facts: Proposed LIBOR Transition Rule Proposed Rule: The LIBOR Transition Proposed Rule would amend certain provisions in Regulation Z, 12 CFR Part 1026, which implements the Truth in Lending Act (TILA) . Proposed effective date: Generally, March 15, 2021. away from London Interbank Offered Rate (LIBOR). Consequently, most LIBOR transition negotiations to date have been included within new fundraisings or borrower-led requests for restatement or amendment of existing facilities. With the expectation that the publication of the London Interbank Offered Rate (LIBOR) will cease by the end of 2021, financial market participants need to be planning the transition of all LIBOR-based exposures to risk-free interest rates in the next six to twelve months. With LIBOR hardwired into trillions of dollars’ worth of financial contracts … Beyond this date the future of LIBOR is not guaranteed. Where are we in the process … Potential project hurdles and their management. The global financial industry is undertaking a significant transformation with the phasing out of London interbank offered rate (LIBOR) and transition to alternative reference rates. There are a number of differences between LIBOR and RFRs which ... averaged over 56,000 contracts daily in early 2020,1 USD156 billion of SOFR swaps have been cleared to date,2 and This creates a wide array of where organizations stand in terms of when they will complete the transition away from LIBOR. Related Posts. I’m joined today by my colleague, Chris Killian, SIFMA managing director, securitization and credit, for a conversation on the transition away from LIBOR and, in particular, the need for federal legislation to aid that transition. The transition away from LIBOR can be widely regarded as one of the biggest challenges faced in the financial industry. The transition from Libor to a new risk-free rate has revealed a number of challenges for all financial markets participants – the nature and scope of what lies ahead is vast, impacting businesses, operations and support functions. The LIBOR transition is a significant event that poses complex challenges for banks and the financial system. Information on the LIBOR Transition at Freddie Mac. Global financial regulators recommend market participants to prepare for the phase out of LIBOR and to work towards adoption of alternative reference rates. M&T Bank has created a dedicated LIBOR Transition Office. The year 2020 is a critical year for preparing for LIBOR cessation. Stay up to date on the transition from LIBOR to alternative reference rates, including SOFR, SONIA, SARON, €STR and TONA. News Articles. This briefing discusses benchmark transition challenges related to LIBOR-based floating rate notes and securitizations and related issues to be To prepare for the anticipated discontinuation of LIBOR, financial institutions have been developing plans for the transition to replacement indices for new and existing loans that use the LIBOR index. Under LMA rate switch provisions in an agreement under which only some or all of 1, 3 and 6 USD LIBOR were applicable as potential interest periods, USD would therefore nonetheless transition on 1 January 2022, since on that date there would be a "Rate Switch Trigger Event Date" for 1 week and 2 month USD LIBOR settings. The rule would make changes to facilitate the LIBOR transition. In the case of LIBOR, the UK Financial Conduct Authority (FCA) has announced that it will not compel or persuade LIBOR panel banks to submit to LIBOR after the end of 2021, calling into question LIBOR’s existence after that date and accelerating efforts to adopt alternative RFRs and fully transition away from LIBOR before it may cease. The London Interbank Offered Rate (LIBOR), is a series of benchmark interest rates and has been called the “world’s most important number.” It is a globally recognized base rate for pricing loans, debt, and derivatives. 2020 2020 Objectives and Paced Transition Plan Best Practice Recommendations Transition from U.S. Dollar LIBOR – Timeline. SEND AN EMAIL. We also note that, based on our reviews to date, the larger the company, the more likely it is to disclose risks related to LIBOR’s expected discontinuation. LIBOR Transition FAQs. EONIA continues to exist under a new methodology since 2 October 2019 to allow a smooth transition to €STR. facilitate the transition from US Dollar LIBOR-based floating rates to SOFR-based floating rates. Organizational choices for cross-functional teams. The transition away from the London Inter-Bank Offered Rate (LIBOR) has been a long and laborious process. As the end of March fast approaches, it brings with it the next important milestone in the transition away from LIBOR. Publication of 1-week and 2-month LIBOR will … In the CME transition, market participants would be able to choose to have the basis swaps booked as either float-versus- ... LIBOR London interbank offered rate MXN TIIE Interbank ‘equilibrium’ benchmark rate calculated by the Mexican Central Bank NPV Net present value Preparing for the LIBOR Transition. Under the amendment approach, the Benchmark Transition Event trigger may require notice of the event by an agent/sole lender and would allow for the amendment process to begin. “These steps represent important milestones in the Enterprises' transition away from LIBOR to a more robust reference rate. LIBOR has played a pivotal benchmarking role in global financial markets for 35 years, but as this role winds down and firms transition to using SOFR and other reference rates, millions of contracts worth hundreds of trillions of dollars must be retooled. Proposed Path Outlines a Clear End Date for USD LIBOR; Would End New Issuances by End-2021, and Subject to Consultation Outcomes, Legacy Contracts Could Mature by Mid-2023. RIN 3170-AB01. There are two parts to the LIBOR fallback language. LIBOR Transition Frequently Asked Questions ... London interbank offered rate (LIBOR) is the most widely used benchmark for short-term interest ... 6 months, and 12 months). Regarding LIBOR transition, the Financial Conduct Authority (FCA), BoE, and the members of the working group on Sterling Risk-Free Reference Rates (RFRs) have issued a joint statement on the impact of coronavirus on banks’ LIBOR transition plans˜, which says: "...end of 2021…should remain the target date for all firms to meet." Mark the Date: Important Announcements by IBA, FCA and ISDA. Docket number CFPB-2020-0014. Adherence to the Protocol is free until the Protocol Effective Date for ISDA members and non-members, though ISDA Primary Members will be charged a $500 fee. Share an update on Standard Chartered’s (“the Bank”) capabilities to transact in Risk-Free Rates (RFR) linked products. The UK regulator has identified the 31st of December 2021 as the watershed date beyond which EUR, CHF, JPY and GBP LIBOR may cease to be published, whereas USD LIBOR may continue till 30 June 2023. EUR LIBOR is expected to cease end 2021. Since 2017, the Financial Conduct Authority, … December 2021 has been etched into our minds for the last 3 years as the end date for LIBOR. To date, the transition has focused on addressing new and legacy contracts referencing LIBOR through incorporation of fallback language; developing sufficient cash and volume in the SOFR-based derivatives markets; and operational requirements to successfully adopt SOFR without significant disruption to … FSB publishes global transition roadmap for LIBOR 16 October 2020. Posted in Bank of England, FCA, ISDA. The PRA is consulting until end-March 2021 on the transition away from LIBOR as regards the rates and spreads used by insurers in calculating the matching adjustment and volatility adjustment. On March 5, 2021, Isda also confirmed that the spread adjustments to be used in its Libor fallbacks will be fixed as of that date, which provides clarity on the future terms of derivative contracts that will incorporate these fallbacks. The pace of the transition has picked up and by now market participants should be finalising their transition plans. Firms must transition to alternative rates before this date. As a key part of the financial services infrastructure, more than $240 trillion in products reference LIBOR.
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