LIBOR reforms — an update

In the January 2013 Risk Note, we set out various proposals that had been published by the FSA in relation to the reform of the regulation and supervision of LIBOR. Since then, the majority of these proposals have been finalised.

On 1 April 2013, the administration of and provision of information to a specified benchmark became a regulated activity for the purposes of the new Regulated Activities Order (the RAO). At present, the RAO limits the definitions of “regulated benchmarks” to LIBOR. However, the new legislation has left it open for the Government to expand these definitions to include other benchmarks in the future.

Shortly before the RAO came into force, the FSA published a Policy Statement (PS13/6) which outlined the regulatory framework it (and now its successor, the Financial Conduct Authority (FCA)) has adopted in relation to the regulation and supervision of LIBOR (the Policy Statement). This new regulatory framework took effect on 2 April 2013…

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