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January 23, 2019

A private-sector working group on euro risk-free rates proposed guiding principles for fallback provisions in new contracts for euro-denominated cash products. The European Central Bank provided the secretariat for the working group. The working group highlighted the importance of market participants adequately preparing for a transition to risk-free rates. The new fallback language, according to the working group, should take into account the following principles: new fallback provisions should include a "permanent cessation trigger event"; "trigger events" should be objective; market

November 28, 2018

In a draft policy note titled The Benchmarks (Amendment) (EU Exit) Regulations 2018: Explanatory Information, the UK Government detailed its approach to "onshoring financial services legislation." The proposed approach would retain and amend EU law so that the EU Benchmark Regulation ("BMR") continues to operate in the UK after the exit date. The proposed approach would: create a UK register for benchmarks, with the UK supervised entities being permitted to use the benchmarks on that register; establish a temporary 24-month transition period for EU-approved benchmarks; beyond that period