August 5, 2022
The Board of Governors of the US Federal Reserve System (the "Board") has proposed regulations ("Proposed Regulations", available here) to implement the Adjustable Interest Rate (LIBOR) Act, which was enacted in March 2022 as "Division U" of the Consolidated Appropriations Act of 2022 (the "LIBOR Act", available here). The purpose of the LIBOR Act is to provide a federal framework that mitigates risks and provides continuity for "tough legacy" contracts that reference the overnight, 1-, 3-, 6-, or 12-month tenors of U.S. dollar LIBOR ("USD LIBOR"). ICE Benchmark Administration ("IBA") has announced it will cease to publish these widely-used benchmark rates after June 30, 2023. The Board is seeking public comments on the Proposed Regulations, which should be submitted by August 29, 2022. The LIBOR Act directs the Board to adopt implementing regulations by mid-September 2022, well in advance of IBA's announced publication end date.