LIBOR® is a benchmark that has historically been determined using input data contributed by a panel of banks. The “panel bank” LIBOR methodology is designed to produce an average rate that is representative of the rates at which large, leading, internationally active banks with access to the wholesale, unsecured funding market could fund themselves in that market in particular currencies for certain tenors.
Immediately prior to December 31, 2021, LIBOR was calculated for five currencies (USD, GBP, EUR, CHF and JPY) and for seven tenors in respect of each currency (Overnight/Spot Next, One Week, One Month, Two Months, Three Months, Six Months and 12 Months), resulting in the publication of 35 individual rates each applicable London business day.
ICE Benchmark Administration Limited (“IBA”) is the authorized and regulated administrator of LIBOR.
LIBOR is in the process of being wound-down:
1 The FCA
these cessations on March 5, 2021.
2 The FCA has confirmed that it expects these settings will continue to be published on a representative basis, using panel bank contributions under the “panel bank” LIBOR methodology, until end-June 2023.
3 The FCA announced these cessations, and advised that it will continue to consider the case for using its new legal powers to require IBA to continue the publication of the 1-, 3- and 6-Months USD LIBOR settings beyond June 30, 2023 under a changed, “synthetic”, unrepresentative methodology.
4 On September 29, 2021. the FCA announced that it would compel IBA to publish these six “synthetic” LIBOR settings for the duration of 2022 (with the first publication being on January 4, 2022). On January 1, 2022, the FCA notified IBA of the changed methodology it requires IBA to use to calculate the “synthetic” LIBOR settings.
Under the BMR, new use of “Article 23A benchmarks” by UK-supervised entities in regulated financial contracts, instruments and/or investment fund performance measurement is prohibited. This includes the “synthetic” 1-, 3- and 6-Months GBP and JPY LIBOR settings. Legacy use of these settings in equivalent circumstances is also prohibited, unless permitted by the FCA. The FCA is permitting all legacy use of 1-, 3- and 6-Months GBP and JPY “synthetic” LIBOR by UK-supervised entities other than in “Cleared Derivatives” (whether directly or indirectly cleared) (as defined in the FCA’s BMR Article 23C notice)5.
From January 1, 2022, the FCA is prohibiting the new use by UK-supervised entities in regulated financial contracts, instruments and/or investment fund performance measurement, of the continuing Overnight and 1-, 3-, 6- and 12-Month USD LIBOR settings, subject to certain exceptions6.
The use of LIBOR in jurisdictions outside the United Kingdom and by entities subject to the oversight of other regulatory authorities may be restricted or prohibited by law in those jurisdictions and by the requirements of such regulatory authorities.
The FCA has published the modifications it has made to the BMR from January 1, 2022 as it applies to the “synthetic” 1-, 3- and 6-Months GBP and JPY LIBOR settings, having regard to the effects of its designations of these six settings as “Article 23A benchmarks” and the imposition of its changes to the methodology for these settings.
Please see the document entitled “Further information on LIBOR” for further information in relation to LIBOR cessation and the exercise by the FCA of its powers under the BMR to compel the publication of “synthetic” LIBOR.
Please also see the FCA’s LIBOR transition website for further information regarding LIBOR transition.
The material and information located on this website is provided for informational purposes only and is not intended to be and should not be relied upon as legal, financial or any other form of advice regarding your use of LIBOR. Please ensure you take legal and financial advice in all relevant jurisdictions to ensure you understand the impact of the cessation or unrepresentativeness of any LIBOR settings on you and your counterparties, and to ensure you understand the implications of the exercise of the FCA’s powers under the BMR.
Waterfall Submission Methodology: Levels
Since December 31, 2021, IBA has determined and published only the Overnight and the 1-, 3-, 6- and 12-Months USD LIBOR settings using panel bank contributions under the “panel bank” LIBOR calculation methodology. No other "panel bank" LIBOR settings have been or will be published after December 31, 2021.
Pursuant to the USD LIBOR Output Statement, each continuing USD LIBOR setting is based on contributions from a panel of large, leading, internationally active banks with access to the wholesale, unsecured funding market for USD. These contributions are determined through the use of a standardised, transaction data-driven waterfall submission methodology introduced by IBA. This submission methodology is designed to produce a rate that is anchored in panel banks’ wholesale, unsecured funding transactions to the greatest extent possible, with a waterfall to enable a rate to be published in all market circumstances. This methodology has been used since March 2019. Details of IBA’s evolution of the “panel bank” LIBOR methodology can be found in the LIBOR documentation section below.
The panel for USD LIBOR is currently composed of 15 panel banks with reference to the USD LIBOR Contributor Bank Criteria, which are designed so that the contributed input data is able to produce a rate that is representative of the economic reality. Each panel bank contributes input data for all five USD LIBOR tenors.
USD LIBOR is calculated in accordance with the USD LIBOR Calculation Methodology using panel bank contributions made in accordance with the USD LIBOR Code of Conduct. The published rate in respect of each tenor is calculated as the arithmetic mean of each panel bank’s contribution in respect of that tenor (after trimming values from the upper and lower quartiles), rounded to five decimal places. Each panel bank's contribution carries an equal weight in the calculation, subject to the trimming.
If IBA receives fewer than the expected number of contributions, the USD LIBOR Reduced Submissions Policy will apply.
|Bank of America N.A. (London Branch)||JPMorgan Chase Bank, N.A. (London Branch)|
|Barclays Bank plc||Lloyds Bank plc|
|Citibank N.A. (London Branch)||MUFG Bank, Ltd|
|Cooperatieve Rabobank U.A.||Royal Bank of Canada|
|Crédit Agricole Corporate & Investment Bank||SMBC Bank International plc|
|Credit Suisse AG (London Branch)||The Norinchukin Bank|
|Deutsche Bank AG (London Branch)||UBS AG|
|HSBC Bank plc|
The FCA is compelling IBA to continue to publish the 1-, 3- and 6-Months GBP and JPY LIBOR settings for the duration of 2022 under a changed, “synthetic” methodology. The FCA requires IBA to use a changed methodology to determine these “synthetic” LIBOR settings as follows:
|"Synthetic” LIBOR||Currency and calculation|
|1 Month||1M ICE TSRR + 0.0326%||1M TORF x (360/365) - 0.02923%|
|3 Months||3M ICE TSRR + 0.1193%||3M TORF x (360/365) + 0.00835%|
|6 Months||6M ICE TSRR + 0.2766%||6M TORF x (360/365) + 0.05809%|
ICE Term SONIA Reference Rate, which is a forward-looking term SONIA reference rate, provided by IBA.
8 With respect to each "synthetic" LIBOR setting, the fixed spread adjustment that applies as part of the ISDA IBOR fallback for each LIBOR setting, and that is published for the purpose of the ISDA 2020 IBOR Fallbacks Protocol and ISDA IBOR Fallbacks Supplement. Bloomberg Index Services Limited maintains and calculates the fixed spread adjustment and the ISDA IBOR fallback for each LIBOR setting - please see the disclaimer here.
9 The Tokyo Term Risk Free Rate, which is a forward-looking term TONA rate, provided by Quick Benchmarks Inc.
Please see the FCA's Article 23D notice for full details of the changes the FCA has imposed on IBA regarding the way that the “synthetic” 1-, 3- and 6-Month GBP and JPY LIBOR settings are calculated.
The “synthetic” LIBOR methodology is not based on panel bank contributions and is not representative of the underlying market or economic reality the setting is intended to measure, including for the purposes of the BMR. IBA no longer publishes the 1-, 3- and 6-Month (or any other tenor) GBP and JPY LIBOR settings using the “panel bank” LIBOR methodology using panel bank contributions.
IBA maintains an oversight committee for LIBOR (for both “panel bank” and “synthetic” LIBOR settings), which has responsibilities under the BMR to oversee the provision of the benchmark.
The committee has broad market representation, being comprised of panel banks, benchmark users, market infrastructure providers, independent non-executive directors of IBA, and other relevant experts. Representatives from the Board of Governors of the Federal Reserve System and the Bank of England also sit on the committee as observers.
LIBOR is normally published at 11:55 am London time on each applicable London business day for all applicable currencies and tenors, except as described below.
There is no LIBOR publication in any currency or tenor if the date is a London public holiday.
Where an otherwise valid publication day is a designated public holiday in the US, there is no publication in the USD LIBOR Overnight tenor only. All other USD tenors are published as normal (this concerns only USD LIBOR).
The FCA requires IBA to publish each “synthetic” LIBOR setting at or around 11:55 am London time on each applicable London business day, except for London public holidays.
The LIBOR Holiday Calendar sets out the relevant London and US public holidays for each LIBOR currency and tenor.
“Panel Bank” LIBOR and “Synthetic” LIBOR
“Panel Bank” LIBOR
Error policy and EME report prior to 01 January 2022
Assurance on Compliance with EU Benchmarks Regulation and Benchmark Methodologies (regarding “panel bank” LIBOR between December 1, 2019 and November 30, 2020)
LIBOR Consultations & Position Papers