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FINAL REGULATION Z RULES FOR LIBOR

On December 8, 2021 the Consumer Financial Protection Bureau (CFPB) amended Regulation Z, which implements the Truth in Lending Act (TILA), generally to address the anticipated sunset of LIBOR, which is expected to be discontinued for most U.S. Dollar (USD) tenors in June 2023. Some creditors currently use USD LIBOR as an index for calculating rates for open-end and closed-end products. The CFPB is amending: The open-end and closed-end provisions to provide examples of replacement […]

STERN REMINDER OF THE END OF LIBOR

On October 5, 2021, Federal Reserve Board Vice Chair for Supervision Randal K. Quarles spoke at The Structured Finance Association Conference in Las Vegas on “Goodbye to All That: The End of LIBOR.” Quarles reminded his audience that while LIBOR will no longer be a functional index after June 30, 2023, it will not be available for use in any new contracts after the end of 2021 — just 85 days from today. The Federal Reserve and […]

INTERAGENCY STATEMENT – CEASE ORIGINATION OF LIBOR-BASED CONTRACTS

On November 30, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a statement to encourage banks to cease entering into new contracts that use USD LIBOR as a reference rate as soon as practicable and in any event by December 31, 2021, in order to facilitate an orderly—and safe and sound— LIBOR transition.

INTERAGENCY STATEMENT ON LIBOR TRANSITION

On November 6, 2020, the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a Statement on Reference Rates for Loans. The statement reiterates that the agencies are not endorsing a specific replacement rate for LIBOR for loans. A bank may use any reference rate for its loans that the bank determines to be appropriate for its funding model and customer needs. However, the bank should […]

CFPB SPRING 2020 AGENDA

On June 30, 2020, the Consumer Financial Protection Bureau (CFPB) published its Spring 2020 Agenda. The agenda lists the regulatory matters that the CFPB expects to focus on between May 1, 2020 and April 30, 2021. Those matters include: A final rule amending the CFPB’s Remittance Rule to provide tailored exceptions that permit certain insured institutions to disclose estimates instead of exact amounts to consumers in certain circumstances. The final rule also increases (from 100 remittance […]