FAQs

LIBOR Transition Update

 

The Alternative Reference Rates Committee (“ARRC“) released additional information regarding its support of the transition from U.S. dollar (“USD“) LIBOR. The ARRC provided a timeline of key milestones. In addition, the ARRC has also released a set of Frequently Asked Questions (“FAQs“) regarding the previously released consultation on USD LIBOR fallback contract language for floating rate notes (“FRNs“). The FRN consultation primarily focuses on new transactions, and, at this time, the ARRC does not intend to produce consultations specifically related to amending outstanding FRNs or other cash products.

The consultation on FRNs and the similar consultation for U.S. syndicated loans are open for public feedback through November 8. (FRN Consultation; U.S. Syndicated Loans Consultation). Comments should be sent to the ARRC Secretariat ([email protected]) no later than November 8. Comments will be posted on ARRC’s website.

SEC Issues FAQs Regarding Rule 15a-6 and Foreign-Broker Dealers

On March 21, the Staff of the  Division of Trading & Markets of the SEC published a set of FAQs on Rule 15a-6 under the Securities Exchange Act of 1934, which provides conditional exemptions from Exchange Act broker-dealer registration requirements for foreign broker-dealers that engage in specified activities involving U.S. investors.  Among the topics covered are distribution of research to U.S. institutional investors, delivery of confirmations and account statements directly to U.S. counterparties, and the application of prior no-action guidance to chaperoning arrangements with non-affiliated broker-dealers.  SEC FAQs.