To whom it may concern,

SIFMA1, AFME2, and ASIFMA3 are pleased to respond to this important consultation on the timeline for the cessation of published LIBOR fixings. Our members have been actively engaged in the LIBOR transition process. We appreciate that IBA is asking for market input on these critically important steps in the transition.

Background

The consultation proposes that the publication of LIBOR fixings would end:

– after the publication of LIBOR on Friday December 31, 2021 for: EUR LIBOR – all tenors (Overnight, 1 Week, 1, 2, 3, 6 and 12 Months); CHF LIBOR – all tenors (Spot next, 1 Week, 1, 2, 3, 6 and 12 Months); JPY LIBOR – all tenors (Spot next, 1 Week, 1, 2, 3, 6 and 12 Months);
GBP LIBOR – all tenors (Overnight, 1 Week, 1, 2, 3, 6 and 12 Months); and USD LIBOR – 1 Week and 2 Months; and
– after the publication of LIBOR on Friday June 30, 2023 for USD LIBOR – Overnight and 1, 3, 6 and 12 Months.

The consultation also states that “Based on current information from panel banks, IBA anticipates there being a representative panel for the continuation of these USD LIBOR settings through to June 30, 2023.”

We support the proposed cessation plan

The finalization of the plan would provide needed certainty to market participants as to the timing of the end of LIBOR. Having a date certain will provide a timeline along which firms can structure their transition plans and budgets, and should encourage firms who have lagged behind in this transition to accelerate their progress. Finally, having a date certain will remove all doubt as to whether LIBOR will actually cease.