LIBOR Transition

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LIBOR Transition

What you need to know to prepare for LIBOR discontinuation.


 

Overview

Invesco, similar to the rest of the global finance industry, is preparing now to discontinue use of LIBOR (London Interbank Offered Rate). Transition from LIBOR to alternative reference rates has already begun and will be completed no later than the end of 2021. LIBOR and other interbank offered rates (IBORs) are used across Invesco and the industry as an interest rate index for financial products, a hedging tool, and a performance benchmark. Despite the current market conditions, the Financial Conduct Authority (FCA), the regulator that oversees LIBOR, has reiterated that organizations should prepare for LIBOR to be phased out by the end of 2021 and for alternative reference rates (ARRs) to be adopted as replacements. 

LIBOR replacements, ARRs, are fundamentally different than LIBOR. The specific qualities of ARRs differ based on jurisdiction, but ARRs are generally overnight risk-free interest rate benchmarks that are considered to be more representative and reliable than LIBOR. This is because these benchmarks are intended to be based on liquid markets, so they can be calculated by reference to actual transactions, opposed to self-reported rates from panel banks as is the case with LIBOR. Common ARRs include SOFR (Secured Overnight Index Average) in the US and SONIA (Reformed Sterling Overnight Index Average) in the UK. Products that reference ARRs are beginning to develop market liquidity and, as part of LIBOR transition, will impact various areas within Invesco.

Invesco has set up a dedicated LIBOR Transition Program to prepare for this transition and determine the overall Invesco impact of LIBOR discontinuance. The LIBOR Transition Program is comprised of global personnel from a variety of impacted areas. The LIBOR Transition Program will provide overall strategic direction to the organization for this significant industry change and will work closely with the applicable internal and external stakeholders to address readiness.

Invesco is committed to ensuring that LIBOR Transition occurs smoothly and with minimal disruption to our clients and stakeholders. If you have any questions regarding LIBOR, Invesco’s preparedness to make the transition to ARRs or any other related topics, please reach out to your primary Invesco representative or point of contact (i.e. relationship manager).

Disclaimer: The information and any opinions expressed on this website are derived from proprietary and non-proprietary sources deemed by Invesco to be reliable, but are not necessarily all-inclusive and may be subject to change. As such, no warranty of accuracy or reliability is given and no responsibility arising in any other way for errors and omissions or actions taken in reliance thereon is accepted by Invesco, its officers, employees or agents.

Frequently Asked Questions

Introduction

The following Frequently Asked Questions (FAQs) have been developed as an educational tool to learn more about one of the most commonly used interest rate benchmarks in the global financial markets, LIBOR. This page includes the following sections:

Background

What is LIBOR?

The London Interbank Offered Rate or “LIBOR” is an interest rate benchmark that is widely used for short-term interest rates, providing an indication of the average rates at which certain banks (referred to as LIBOR “panel banks”) could borrow from other banks on an unsecured basis for set periods of time and in particular currencies. LIBOR is based on submissions from panel banks of the rates they either pay or would expect to pay to borrow from other banks.

What is the difference between IBOR and LIBOR?

Interbank Offered Rate (IBOR) is a broad term which defines various reference rates used to determine the rate at which banks can lend and borrow from one another. For example, reference rates such as: EURIBOR, TIBOR and LIBOR could all be referred to as IBORs. The term LIBOR refers to a specific IBOR which is based on submissions from panel banks and denominated in five currencies (CHF, EUR, GBP, JPY and USD).

How is LIBOR used?

  1. To calculate interest payments for products such as loans, derivatives and bonds.

  2. As a performance target or benchmark for investment funds.

  3. To value certain products.

  4. In investment objectives.

  5. To calculate discount rates or performance ratios.

  6. To assess market expectations regarding central bank interest rates and liquidity in the interbank lending market.

  7. As an indicator of the health of the banking system.

  8. For operational activities, including valuation curves, stress testing, pricing and asset allocation models.

Why is LIBOR important?

LIBOR is by far the most prevalent floating rate index worldwide. For example, if a loan has a floating rate (an interest rate that fluctuates over the duration of the contract), then that interest rate will often be based on LIBOR. LIBOR is most frequently used for derivatives, which make up approximately 90% of the roughly US$350 trillion worth of financial products linked to LIBOR.


What currencies and time periods are used for LIBOR?

LIBOR is currently produced for five currencies (CHF, EUR, GBP, JPY and USD) and seven tenors or time periods (Overnight/Spot Next, 1 Week, 1 Month, 2 Months, 3 Months, 6 Months and 12 Months). A total of 35 rates across tenors and currencies are published every applicable London business day. Currently, each LIBOR calculation is based on interest rates (input data) received from a group of between 11 and 16 panel banks for each of the five LIBOR currencies.

When will LIBOR be phased out?

The Financial Conduct Authority (FCA), the regulator that oversees LIBOR, has indicated that it will no longer persuade or compel panel banks to submit the rates required to calculate LIBOR after the end of 2021. The Transition from LIBOR to alternatives reference rates has begun and will be competed no later than the end of 2021. Regulators are encouraging firms and investors to transition away from the use of LIBOR to new rates as soon as they are able to and have created interim milestones to promote early adoption. Thus, Invesco and other market participants are taking action now to address LIBOR discontinuation. As recent as March 25, 2020, the FCA has confirmed in light of the COVID-19 pandemic that "the central assumption that firms cannot rely on LIBOR being published after the end of 2021" has not changed and should remain the target date for all firms to meet. (Link)

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Changes

What caused the need to stop using LIBOR?

The integrity of LIBOR was questioned during the 2008 financial crisis when several banks contributing to its calculation were accused of rate manipulation. A contraction in the unsecured interbank lending market has also occurred in the years since the financial crisis. Attempts to base LIBOR on actual transactions failed, as the underlying market which LIBOR seeks to measure is no longer sufficiently active. However, the FCA will ensure that panel banks continue to submit rates to LIBOR’s administrator so that LIBOR can be calculated until the end of 2021, at which time LIBOR is expected to be discontinued and alternative reference rates (ARRs) will be utilized in its place. By contrast, these ARRs are based on overnight lending markets rates, which are generally considered to be more liquid.

What are the inherent issues with LIBOR and how will they be addressed in LIBOR’s replacement?

LIBOR is inherently subjective as panel bank submissions are not necessarily rooted in actual transactions or data. Despite governance put into place since the financial crisis, LIBOR still relies on bank estimates. The LIBOR replacements differ in how they function across the world (more on that in the Alternative Reference Rates section), but they seek to improve objectivity and transparency by being rooted in a large volume of actual transactions.

Who governs the LIBOR transition?

Working groups have been established in each of the jurisdictions that have LIBOR produced in their currency. For each currency LIBOR variant, the working groups have identified an alternative reference rate and are developing plans to transition each market to the new ARRs. In some jurisdictions, the new ARRs may coexist alongside the relevant IBORs, such as EURIBOR in Europe and JPY TIBOR in Tokyo, in a multi-rate environment. While each working group is focused on their specific currency transition, there is a global effort to work across jurisdictions in recognition of the global impacts of LIBOR transition. The working group in the US is the Alternative Reference Rate Committee (ARRC) and in the UK is the Working Group on Sterling Risk-Free Reference Rates. Additionally, the International Swaps and Derivatives Association, Inc. (ISDA) is focused on the transition of the derivatives markets to ARRs.


What else is changing?

Some IBORs are being reformed so that they are calculated wherever possible by reference to actual transactions (e.g. EURIBOR and JPY TIBOR). While these IBORs may continue to exist alongside the relevant ARRs, it is expected that other IBORs will be permanently discontinued as early as January 2022.


Why is the transition from LIBOR a challenge?

There are multiple challenges as part of the transition. While firms are pivoting away from LIBOR in new transactions, trillions of dollars of legacy debt and derivatives products will continue to reference the benchmark after the 2021 deadline, when the relevant LIBOR may be discontinued. Additionally, ARRs and LIBORs are distinctly different. No ARR will be equivalent to the related LIBOR because of structural differences between the two. Investment and operational processes will need to adapt to address these issues.

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Replacements

Which rates are likely to replace LIBOR?

Alternative reference rates (ARRs) are likely to replace LIBOR. ARRs differ based on jurisdiction but generally are overnight interest rate benchmarks which are perceived by regulators to be more representative and reliable than LIBOR. This is because these benchmarks are intended to be based on liquid markets and so they can be calculated by reference to actual transactions. The table below shows the proposed replacement ARRs across currencies.

LIBOR Currency

Proposed Alternative Reference Rate

US Dollar

SOFR (Secured Overnight Financing Rate)+

Sterling

SONIA (Sterling Overnight Index Average)*

Euro**

€STR (Euro Short-Term Rate)*

Swiss Franc

SARON (Swiss Average Rate Overnight)+

Japanese Yen***

TONAR (Tokyo Overnight Average Rate)*

+ Based on secured transactions
* Based on unsecured transactions
**Reformed EURIBOR may be an additional potential reference rate
***JPY TIBOR may be an additional potential reference rate
 

When can these ARRs be used?

Many ARRs are already available to trade, with market liquidity gradually increasing. The transition plans have been published by the working groups responsible for overseeing the transition (i.e. the ARRC in the US for SOFR and the Working Group on Sterling Risk-Free Reference Rates in the UK for SONIA).

How similar are the ARRs across currencies?

They vary. Some ARRs are secured (i.e. based on actual overnight transactions and secured by collateral), while others are unsecured. Additionally, the ARRs have unique market reference points (i.e. SONIA is based on overnight wholesale deposit transactions, while SOFR is based on multiple overnight Treasury repo market segments).

What are the replacements for other IBORs (not just LIBOR)?

As noted above, EURIBOR in the eurozone and JPY TIBOR in Japan are expected to exist in 2022 and beyond. Additionally, BBSW in Australia, CDOR in Canada, HIBOR in Hong Kong and SIBOR in Singapore are expected to exist in 2022 and beyond, in addition to the ARRs in these currencies. It is possible that some market participants may choose to use IBORs. However, some of these IBORs are subject to reform because they suffer from similar issues to LIBOR; thus market participants may prefer to use ARRs instead. The replacements for IBORs continues to be discussed throughout the industry.

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Alternative Reference Rates

How are the proposed alternative reference rates (ARRs) different than LIBOR?

The ARRs differ from LIBOR in three main ways:

1

ARRs are overnight rates which are published at the end of the overnight borrowing period. This means they are “backward-looking.” In contrast, LIBOR is a term rate (i.e., it is a rate to borrow for a period of time such as 3 months or 6 months) and it is published at the beginning of the borrowing period. This means LIBOR is “forward-looking.

2

LIBOR also includes a premium for interbank credit risk (i.e., an additional amount to account for the risk that the borrowing bank may not be able to repay the interbank borrowed from). ARRs, which are overnight rates and, in some cases, secured do not include this premium or include a reduced premium.

3

LIBOR also measures the same market in all currencies. The ARRs measure different markets. For example, the ARRs for US Dollar and Swiss Franc are based on secured markets whereas the ARRs for Sterling, Japanese Yen and Euro are based on unsecured markets. This means that different ARRs are likely to behave slightly differently.

What impact will this change have?

LIBOR discontinuation will result in two primary impacts that investors should be aware of. Note that this list is not exhaustive, rather a summary of high-level areas impacted.

Value Transfer

Benchmarks and Strategy


There may be significant changes to the valuation of LIBOR-based portfolios (i.e., value transfer) as no replacement benchmark is likely to be neutral to all industry participants and counterparties, and due to the uncertainty surrounding the future liquidity of LIBOR markets.
 



Certain investment strategies and hedging might require revisions to address changes in liquidity post LIBOR transition. Updates to performance benchmarks for LIBOR based funds will also be required.
 

 
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SOFR

Who is in charge of the transition process away from LIBOR for USD-denominated instruments to SOFR, the USD LIBOR replacement and ARR?

The Alternative Reference Rates Committee (ARRC) is overseeing the transition and will lead the transition away from LIBOR in the US. The ARRC is a group of private-market participants initially convened by the Federal Reserve (Fed) in December 2014, in cooperation with other US federal financial services regulatory authorities. The list of 2020 ARRC objectives can be found at this link. Additionally, ISDA is leading the transition of the USD LIBOR derivatives markets to SOFR.

Who produces and administers SOFR?

The New York Fed publishes SOFR on its website on a daily basis, at approximately 8 a.m. EST. SOFR represents a broad measure of the cost of borrowing cash overnight in the repo market collateralized by Treasury securities. Publication of SOFR began in April 2018.

Is SOFR available to use now?

Yes. SOFR based floating rate notes and bonds are available, albeit in limited amounts, as are a limited amount of SOFR-based derivatives. As LIBOR discontinuance nears, market adoption and liquidity is expected to grow.

What are the differences between LIBOR and SOFR?

LIBOR and SOFR are fundamentally different in several ways, such as how they are calculated and administered. Below is a comparison:

Characteristic

SOFR

LIBOR

Risk

Risk free rate (no credit risk)

Bank lending rate (includes credit risk)

Forward vs. Backward Looking

Overnight (backward looking)

Forward looking

Secured vs. Unsecured

Secured (collateralized)

Unsecured (no collateral)

Calculation and Publication

Calculated and published daily by the NY Fed

Calculated and published daily by ICE Benchmark Administration

Basis

Transaction based

Based on LIBOR panel banks

Term Structure

No term structure

Term structure

What are some of the consequences of moving from LIBOR to SOFR?

While there are many implications as a result of moving from LIBOR to SOFR, one of the most critical impacts is that an unintended “value transfer” can occur when transitioning existing LIBOR-based financial products to SOFR, as no replacement benchmark is likely to be neutral to all industry participants and counterparties. The ARRC has addressed the value transfer that is expected to occur by recommending a credit spread adjustment be added to SOFR when SOFR is used to replace LIBOR in an existing financial product. On April 8, 2020, the ARRC recommended a credit spread adjustment calculation methodology for cash products referencing USD LIBOR. This spread adjustment methodology is based on a historical median over a five-year lookback period calculating the difference between USD LIBOR and SOFR. This methodology aligns with ISDA’s recommended credit spread adjustment methodology for derivatives.

How has SOFR performed relative to LIBOR with the recent market downturn?

On March 27, 2020, some repo transactions used in the calculation of SOFR traded at negative rates, which is the lowest since the benchmark started printing in April 2018. In many cases LIBOR and SOFR have moved in opposite directions. The large difference between the current level of spot LIBOR / SOFR basis and the historical median spread highlights the challenge of not including a transition period when incorporating LIBOR fallback language. Were LIBOR to discontinue at a time of such large disparity between the historical and spot spreads between LIBOR and SOFR, there would be an arbitrary step change in the value of LIBOR-indexed financial products. Including a transition period such as one year would mitigate this by smoothing out the change over a specified time.

 

Is there a timeline for adoption of SOFR?

Yes. The ARRC published a Paced Transition Plan which outlines key operational milestones until the end of 2021 to promote SOFR’s adoption. In both 2019 and 2020, the ARRC also issued a complementary Incremental Objectives document which outlines key priorities and milestones to be met in order to support and prepare market participants for the transition. Note that a transition period for fallback language has not been published yet.

How can I learn more about SOFR?

Additional resources can be found on the ARRC website, such as “A User’s Guide to SOFR” that details how to use SOFR in cash products.

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SONIA

What is SONIA?

The Reformed Sterling Overnight Index Average (SONIA) is the ARR for the British Sterling currency. SONIA is a measure of the rate at which interest is paid on unsecured overnight sterling transactions.

Who is in charge of the transition process away from LIBOR for GBP-denominated instruments to SONIA?

The Working Group on Sterling Risk-Free Reference Rates is overseeing the transition and will lead the transition away from LIBOR in the UK. This working group was established in 2015 and in April 2017 recommended the SONIA benchmark as the preferred ARR. Since then, the working group has been focused on how to transition to using SONIA across sterling markets.

Who produces and administers SONIA?

The Bank of England (BoE), supported by the SONIA Oversight Committee and SONIA Stakeholder Advisory Group, publishes SONIA on its website each London business day at 9:00am local time. In addition to the headline rate, additional rates at percentiles of volume are provided. Publication of SONIA began in 1997, was taken over by the BoE in 2016 and was reformed in April 2018.

Is SONIA available to use now?

Yes. SONIA is available across a variety of instruments. SONIA is currently used to value around £30 trillion of assets each year, and is the benchmark floating rate used in GBP overnight index swaps (OIS). As LIBOR discontinuance nears, market adoption and liquidity is expected to grow. 

Why was SONIA chosen as the preferred alternative to LIBOR?

  1. SONIA has the capability to evolve over time so it is robust to changes in its underlying markets.

  2. SONIA tends to be predictable.

  3. SONIA is referenced in the already liquid sterling overnight indexed swap (OIS) market making transition easier.

What are the differences between LIBOR and SONIA?

LIBOR and SONIA are fundamentally different in several ways, such as how they are calculated and administered. Below is a comparison:

Characteristic

SONIA

LIBOR

Risk

Risk free rate (no credit risk)

Bank lending rate (includes credit risk)

Forward vs. Backward Looking

Overnight (backward looking)

Forward looking

Secured vs. Unsecured

Unsecured (no collateral)

Unsecured (no collateral)

Calculation and Publication

Calculated and published daily by the BoE

Calculated and published daily by ICE Benchmark Administration

Basis

Transaction based (calculated by overnight wholesale sterling deposit transactions)

Based on LIBOR panel banks

Term Structure

No term structure (however term in SONIA is scheduled to be available in Q3 2020)

Term structure

What are some of the consequences of moving from LIBOR to SONIA?

Similar to what was described in the “SOFR” section above, one of the most critical impacts in the transition from LIBOR to SONIA is that an unintended “value transfer” can occur when transitioning existing LIBOR-based financial products to SONIA, as no replacement benchmark is exactly the same as LIBOR. Because SONIA is an overnight rate and has a different credit spread compared to LIBOR, the Working Group on Sterling Risk-Free Reference Rates recommend the use of a static credit spread adjustment that may result in value transfer. In December 2019, the Working Group on Sterling Risk-Free Reference Rates published a consultation paper wherein four credit spread adjustment calculation methodologies were evaluated (Link). The Working Group on Sterling Risk-Free Reference Rates came to the determination that the historical 5 year median approach was the “most appropriate methodology for credit adjustment spreads in both cessation and pre-cessation fallbacks for sterling Libor linked cash products maturing beyond end 2021.”* This methodology also aligns with ISDA’s recommended credit spread adjustment methodology for derivatives.

*Refer to the Bank of England’s website for further details, specifically the section, “Summary of responses - Consultation on credit adjustment spread methodologies for fallbacks in cash products referencing GBP LIBOR.”

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Fallback Language

What is a “fallback”?

A “fallback” refers to the language in a contract that lays out the process through which a replacement interest rate will be identified and implemented if the benchmark interest rate (e.g., USD 3-month LIBOR) referenced in the contract is (x) permanently discontinued (a permanent cessation fallback) or (y) announced by an official source to be no longer representative of the underlying market (a pre-cessation fallback). Fallback language within a contract acts as a how-to guide for identifying the replacement interest rate should the original benchmark rate be unavailable or non-representative. For example, a USD LIBOR fallback provision would have the contract switch to SOFR as the benchmark rate plus a defined credit spread adjustment upon LIBOR becoming unavailable or non-representative.

Who is assisting in proposing new fallback language?

Industry associations have mobilized around LIBOR fallback language reform, with the ISDA leading efforts globally for derivatives. Additionally, national working groups have been engaged on similar enhancements for cash products, most prominently led by the US focused ARRC. The diagram below outlines the working groups across the LIBOR currencies. Both ISDA and national working groups make recommendations regarding fallback language for market participants’ voluntary use in contracts with the goal of reducing the risk of serious market disruption in the event that the relevant LIBOR is no longer usable. Feedback on proposed fallbacks is generated via industry wide consultations.

Jurisdiction      
Working Group  
Administrator   
ARR                  
Fallback Language Resources          

USD LIBOR

Federal Reserve Bank of New York

Secured overnight financing rate (SOFR)


GBP LIBOR

Bank of England

Reformed Sterling overnight index average (SONIA)

Consultation on Credit Adjustment Spread Methodologies for Fallbacks in Cash Products Referencing GBP LIBOR – Summary (Link)
 
 
 
 
 
 

EURIBOR, Euro LIBOR

European Central Bank

Euro short-term rate (€STER)


CHF LIBOR

SIX Exchange

Swiss average rate overnight (SARON)

n/a
 
 
 
 
 
 
 
 
 
 

JPY LIBOR, JPY TIBOR, Euroyen TIBOR

Bank of Japan

Tokyo overnight average rate (TONA)

n/a

What has ISDA done to assist the market with transitioning away from LIBOR for derivatives?

ISDA has been working on an initiative at the request of the Financial Stability Board’s Official Sector Steering Group (FSB OSSG) since 2016 to identify robust fallbacks for derivatives contracts that reference LIBOR. ISDA conducted several industry consultations since 2018 to finalize the methodology for permanent cessation and pre-cessation fallbacks.

What have been the results from key previous ISDA consultations?**

September 2019: Based on feedback received, ISDA will proceed in developing fallbacks for inclusion in its standard definitions based on the compounded setting in arrears rate and the historical median approach to the spread adjustment for USD LIBOR, CDOR and HIBOR. (Link)

November 2019: This consultation finalized the use of a historical median approach over a five-year lookback period and the compounded setting in arrears rate. Coming out of this consultation, ISDA will make the relevant amendments to the 2006 ISDA Definitions to incorporate fallbacks with these adjustments for new LIBOR trades. Bloomberg was selected to publish the adjustments and ‘all in’ fallback rates. ISDA will also publish a protocol to enable market participants to include fallbacks within legacy LIBOR derivative trades if they choose to. (Link)

May 2020: The results of this consultation on pre-cessation fallbacks indicated that a significant majority of respondents are in favor of including both pre-cessation and permanent cessation fallbacks as standard language in the amended 2006 ISDA Definitions for USD LIBOR and in a single protocol for including the updated definitions in legacy trades. (Link)

**Note there have been additional consultations in 2019 and 2018. Additional information can be found at the provided links.

What has the Alternative Reference Rate Committee (ARRC) done to assist the market with transitioning away from LIBOR for cash products?

ARRC has conducted consultations for fallback language for various USD LIBOR based cash products and has proposed credit spread adjustment methodologies for fallbacks. The following products have had fallback language consultations to date: adjustable rate mortgages, bilateral business loans, floating rate notes, securitizations, syndicated loans, and variable rate private student loans. Once public feedback is reviewed from a consultation, the ARRC releases final recommendations on fallback language that can be incorporated into USD LIBOR contracts for market use (note that adoption of ARRC proposed fallback language is voluntary).

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Impacts

What is Invesco doing to understand the potential impacts of LIBOR discontinuation and transition to ARRs on clients?

Invesco is committed to working closely with regulators, market participants and industry bodies. Invesco is also participating in industry discussions and following developments in evolving areas so that Invesco can adopt approaches and strategies that are consistent with industry best practices.

In order to assess the impact of LIBOR transition on client portfolios and to prepare for the transition, Invesco is undertaking a review across all investment teams that manage portfolios with LIBOR exposure. This review aims to determine the type and scope of that exposure and to assess the applicable LIBOR transition options.

What will Invesco be doing to mitigate the potential impacts of LIBOR discontinuation and transition to ARRs on clients?

Invesco supports the market transition away from LIBOR and is committed to keeping clients informed of the potential impacts. Invesco has established a comprehensive global LIBOR transition program with a dedicated team of subject matter experts to manage the impact of the transition.

While Invesco’s internal planning and due diligence on these changes has already started, it is not yet possible to accurately determine the precise impact on clients and businesses. Invesco is monitoring this situation and, where required, will update this website with further information.


What is Invesco’s approach to LIBOR transition in light of COVID-19?

Invesco is continuing to work towards the transition away from LIBOR for all clients by the end of 2021 at the latest, in line with statements from global regulators. Invesco aims to ensure an effective LIBOR transition for clients and the firm by the end of 2021. Invesco is continually assessing how the transition may impact LIBOR-referencing investments, while closely monitoring regulatory and market developments.

Do clients need to do anything now?

Invesco is proactively preparing for LIBOR transition and encourages clients to do so as well. Although the full impact of the reforms is still unclear, there are a number of potential steps that clients may wish to take now:

  • Consider the latest industry information available on LIBOR transition.
  • Identify any investments that reference LIBOR and engage with Invesco to the extent that there is uncertainty regarding the potential impact on those investments.
  • Consider seeking advice from professional advisers on the possible implications of the changes from a financial, legal, accountancy or tax perspective.

Where can I obtain more information?

Invesco will seek to update this page periodically as market developments occur and industry announcements are made. In addition, should you seek general information on LIBOR transition, please consider reviewing published information from regulators, working groups and other industry bodies.

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Disclaimer: The information and any opinions expressed on this website are derived from proprietary and non-proprietary sources deemed by Invesco to be reliable, but are not necessarily all-inclusive and may be subject to change. As such, no warranty of accuracy or reliability is given and no responsibility arising in any other way for errors and omissions or actions taken in reliance thereon is accepted by Invesco, its officers, employees or agents.