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Webinar: Managing Down Model Validation Costs

webinar

Managing Down Model Validation Costs

Learn how to make your model validation budget go further for you.  In this webinar, you’ll learn about:  Balancing internal and external resources, prioritizing models with the most risk, documenting to facilitate the process.

About The Hosts

Timothy Willis

Managing Director – RiskSpan

Timothy Willis is an experienced engagement manager, financial model validator and mortgage industry analyst who regularly authors and oversees the delivery of technical reports tailored to executive management and regulatory audiences. Tim has directed projects validating virtually every type of model used by banks. He has also developed business requirements and improved processes for commercial banks of all sizes, mortgage banks, mortgage servicers, Federal Home Loan Banks, rating agencies, Fannie Mae, Freddie Mac, and U.S. Government agencies.

Nick Young

Director of Model Risk Management

Nick Young has more than ten years of experience as a quantitative analyst and economist. At RiskSpan, he performs model validation, development and governance on a wide variety of models including those used for Basel capital planning, reserve/impairment, Asset Liability Management (ALM), CCAR/DFAST stress testing, credit origination, default, prepayment, market risk, Anti-Money Laundering (AML), fair lending, fraud and account management.

Webinar: Mortgage Insurance and CECL Presented by MGIC with RiskSpan

webinar

Mortgage Insurance and CECL – Presented by MGIC with RiskSpan

Mortgage insurance is typically purchased to protect mortgage investors from credit risk. Under the new “Current Expected Credit Loss” (CECL) accounting standard, mortgage insurance provides a secondary benefit: a lower allowance for credit losses.

This webinar will:

  • Quantify the impact of MI on CECL under a range of macroeconomic scenarios
  • Introduce a way of measuring MI “value” in a CECL context, namely, a premium-to-allowance reduction ratio
  • Under a mainstream set of macroeconomic assumptions, analyze various coverage levels to search for best value

Webinar: Practical Approaches for Debt Securities Accounting

webinar

Practical Approaches for Debt Securities Accounting

Join RiskSpan allowance expert David Andrukonis for lessons learned from early Current Expected Credit Loss standard (CECL) adopters. 2020 CECL adopters are ready for the new loan accounting, but many are scrambling to meet the new requirements for their HTM and AFS debt securities.

This session will give you:

  • Concrete, practical approaches to solve for HTM and AFS credit loss accounting – approaches that can still be implemented in time for the 2020 adoption deadline and parallel runs
  • CECL implementation experiences from small banks up to $150bn firms, with both 2020 and 2023 implementation dates
  • Solutions for all security types, across a range of budgets
  • Q&A with the host, David Andrukonis

About The Hosts

David Andrukonis, CFA

Managing Director

David Andrukonis has technical and managerial experience in banking, credit risk, and valuation. At RiskSpan, David performs non-traditional ABS valuations and has validated a wide range of financial forecasting models, including models that estimate return on equity, capital levels, asset/liability valuations, and loan losses.


Webinar: Using Machine Learning in Whole Loan Data Prep

webinar

Using Machine Learning in Whole Loan Data Prep

Tackle one of your biggest obstacles: Curating and normalizing multiple, disparate data sets.

Learn from RiskSpan experts:

  • How to leverage machine learning to help streamline whole loan data prep
  • Innovative ways to manage the differences in large data sets
  • How to automate ‘the boring stuff’

About The Hosts

LC Yarnelle

Director – RiskSpan

LC Yarnelle is a Director with experience in financial modeling, business operations, requirements gathering and process design. At RiskSpan, LC has worked on model validation and business process improvement/documentation projects. He also led the development of one of RiskSpan’s software offerings, and has led multiple development projects for clients, utilizing both Waterfall and Agile frameworks.  Prior to RiskSpan, LC was as an analyst at NVR Mortgage in the secondary marketing group in Reston, VA, where he was responsible for daily pricing, as well as on-going process improvement activities.  Before a career move into finance, LC was the director of operations and a minority owner of a small business in Fort Wayne, IN. He holds a BA from Wittenberg University, as well as an MBA from Ohio State University. 

Matt Steele

Senior Analyst – RiskSpan

LC Yarnelle is a Director with experience in financial modeling, business operations, requirements gathering and process design. At RiskSpan, LC has worked on model validation and business process improvement/documentation projects. He also led the development of one of RiskSpan’s software offerings, and has led multiple development projects for clients, utilizing both Waterfall and Agile frameworks.  Prior to RiskSpan, LC was as an analyst at NVR Mortgage in the secondary marketing group in Reston, VA, where he was responsible for daily pricing, as well as on-going process improvement activities.  Before a career move into finance, LC was the director of operations and a minority owner of a small business in Fort Wayne, IN. He holds a BA from Wittenberg University, as well as an MBA from Ohio State University. 

Webinar: Estimating Credit Losses in the COVID-19 Pandemic

webinar

Estimating Credit Losses in the COVID-19 Pandemic

Business-as-usual macroeconomic scenarios that seemed sensible a few months ago are now obviously incorrect. Off-the-shelf models likely need enhancements. How can institutions adapt? 

In this webinar, we will discuss:   

  • How to incorporate COVID-19-driven macroeconomic scenarios in an allowance model (for CECL and OTTI attributions)
  • Making necessary enhancements and tunings to credit and prepayment models
  • Model overrides and user-defined scenarios
  • Situations in which management “Q-factor” or qualitative adjustments may be called for

Webinar: Modeling Techniques for Hard-to-Value Bonds

webinar

Modeling Techniques for Hard-to-Value Bonds

Learn from leading practitioners as they discuss how to model bonds whose market values do not reflect their underlying fundamentals.

The market continues to punish every category of structured finance product. Even the highest-rated securities are not immune, but the further a bond moves down the ratings scale, the greater the uncertainty around what its real valuation is. 

Mark-to-model is fast becoming the new normal as the Covid-19 crisis is causing investors to become less and less comfortable relying on normal pricing service output. But transitioning from Level 1 to Level 2 (and even sometimes Level 3) assets brings with it a host of internal compliance and other challenges.  

Modelers must be able to demonstrate that their assumptions are defensible and their techniques are sound. 

Join Bill Moretti, Scott Carnahan, and Joe Sturtevant as they discuss “Modeling Techniques for Hard-to-Value Bonds” 

Key Topics:  

  • Overview of recent cross-sector performance 
  • Considerations when having to adapt from a market-based approach to a model-based one 
  • Example illustration of how to value a CLO security using mark-to-model. 

Understanding the Impact of Federal Reserve Emergency Rate Cuts

Disruptions to the U.S. and global economy brought about by COVID-19 have prompted the Federal Reserve to take a number of emergency measures. These include twice cutting the federal funds rate (to near zero), resuming its purchase of securities, and temporarily relaxing regulatory capital and liquidity requirements (among several other things).  

Although the Fed’s actions take many forms, few things capture investors’ attention in the way emergency rate cuts do. Predicting how financial markets will respond to these cuts is a complicated undertaking. To help investors analyze how these events have affected markets historically, RiskSpan has developed a tool to help investors visualize how various market indices, commodities, currencies and bond yields have reacted to emergency Fed rate cuts in the wake of various market shocks. 

Analyzing events in this way enables investors to more effectively manage their portfolio risk by monitoring market–moving events and identifying response patterns. We analyze a range of past market events to formulate scenarios for RiskSpan’s RiskDynamics market risk service. 

Every crisis is unique, of course. But the Fed’s interest rate cuts this month are specifically reminiscent of seven actions it has taken in response to past economic threats, including the Russian Ruble crisis (2014), the bursting of the dot-com bubble (2000), the September 11th attacks (2001), and the subprime mortgage/Lehman Brothers collapse (2008). 

The chart below compares the response of the S&P 500 to the Lehman collapse and COVID-19 and how long it takes the ensuing Fed rate cut to affect the market. The similarity in the shape of these two curves is quite striking. It also reflects the time required for Congress to pass stimulus following Fed action. 

federal reserve impact shown in RS Edge

The tool displays the performance of several markets across three asset classes in response to each of the seven Fed cuts. In this version we have included stocks, rates and commodities. The two interactive charts specifically help to visualize the following: 

  1. Performance of asset classes from 20 days before through 60 days following each rate cut. 
  2. Performance indexed to the event date—helping to illustrate market conditions leading up to the rate cut and its subsequent impact. 
  3. Daily returns enabling a cross-sector, cross-market comparisons to each rate cut. 

Additional patterns also emerge when looking at how markets have responded to these seven prior cuts: 

  • Equity market collapses tend to stall, but the recovery (if any) is slow. 
  • The volatility index stabilizes, but it takes time to mean revert. 
  • Treasury bonds generally perform better than other asset classes. Long–dated bonds don’t perform as well. 
  • Crude oil continues to sell off in most cases. 

We are continually expanding the list of asset classes and events covered by the tool. Our data science team is also working some interesting analytics for publication.  

We welcome your feedback and requests for additional analysis. Please contact us to discuss further. 

¹ In 2011-12, the market saw significant differences in buyout behavior, for example Bank of America was slow to buy out delinquent loans.

² On Bloomberg, the delinquency states 90 days onward are compressed into a single 90+ state.

Visualizing a CMBS Portfolio’s Exposure to COVID-19

he economic impact of the Coronavirus outbreak is all but certain to be felt by CMBS investors. The only real uncertainty surrounds when missed rent payments will begin, what industries are likely to feel them most acutely, and—more to the point—how your portfolio aligns with these eventualities.

The dashboard below—created using RS Edge and Tableau—displays a stylized example compiling small random excerpts from several CMBS portfolios. While business disruptions have not (yet) lasted long enough to be reflected in CMBS default rates, visualizing portfolios in this way provides a powerful tool for zeroing in on where problems are most likely to emerge.

The maps at the top of the dashboard juxtapose the portfolio’s geographic concentration with states where COVID-19 prevalence is highest. Investors are able to drill down not only into individual states but into individual NAICS-defined industries that the loans in their deals cover.

At each level of analysis (overall, by state, or by industry) the dashboard not only reports total exposure in UPB but also important risk metrics around the portfolio’s DSCR and LTV, thus enabling investors to quickly visualize how much cushion the underlying loans have to absorb missed rent payments before the deals begin to experience losses.

COVID-19-portfolio-exposure-in-RS-Edge

The real value of visualizations like these, of course, is the limitlessness of their flexibility and their applicability to any market sector.

We sincerely desire to be helpful during these unprecedented market conditions. Our teams are actively helping clients to manage through them. Whether you are looking for historical context, market analysis or just a conversation with folks who have been through several market cycles, we are here to provide support. Please contact us to talk about what we can do for you.

RiskSpan VQI: Current Underwriting Standards – February 2020

riskspan-VQI-report

The RiskSpan Vintage Quality Index (“VQI”) edged higher for mortgages originated during February despite remaining low (90.41) by historical, pre-crisis standards. Low-FICO and high-LTV loans continued to trend downward, while high-DTI loans, investment properties, and cash-out refinances continued to rebound after declining through much of 2019.

As the historical trend of risk layering (see below) shows, mortgages with one borrower—now accounting for more than 50 percent of originations—remain a consistent and important driver of the index. High-DTI loans today drive the index more than they did during the years immediately after the 2008 crisis but not nearly so much as they did during the years leading up to it. High-LTV loans continue to be originated in abundance, while adjustable-rate mortgages and loans with subordinate financing, in contrast, have practically vanished.

riskspan-VQI-report

RiskSpan introduced the VQI in 2015 as a way of quantifying the underwriting environment of a particular vintage of mortgage originations. The idea is to provide credit modelers a way of controlling for a particular vintage’s underwriting standards, which tend to shift over time. The VQI is a function of the average number of risk layers associated with a loan originated during a given month. It is computed using:

  1. The loan-level historical data released by the GSEs in support of Credit Risk Transfer initiatives (CRT data) for months prior to December 2005, and
  2. Loan-level disclosure data supporting MBS issuances through today.

The value is then normalized to assign January 1, 2003 an index value of 100. The peak of the index, a value of 139 in December 2007, indicates that loans issued in that month had an average risk layer factor 39% greater (i.e., loans issued that month were 39% riskier) than loans originated during 2003. In other words, lower VQI values indicate tighter underwriting standards (and vice-versa).

Build-Up of VQI

The following chart illustrates how each of the following risk layers contributes to the overall VQI:

  • Loans with low credit scores (FICO scores below 660)
  • Loans with high loan-to-value ratios (over 80 percent)
  • Loans with subordinate liens
  • Loans with only one borrower
  • Cash-out refinance loans
  • Loans secured by multi-unit properties
  • Loans secured by investment properties
  • Loans with high debt-to-income ratios (over 45%)
  • Loans underwritten based on reduced documentation
  • Adjustable rate loans
riskspan-VQI-report
riskspan-VQI-report
riskspan-VQI-report

Guide to the LIBOR Transition

Guide to the LIBOR Transition

CONTRIBUTORS

Patrick Greene
Managing Director

Rachel Fetrow
Analyst

TABLE OF CONTENTS

  1. What is LIBOR?

  2. Why is LIBOR Changing?

  3. What are regulators proposing is the solution?

  4. What is SOFR?

  5. Who does this transition affect?

  6. References

Have questions about LIBOR?

Talk Scope

Chapter 1
What is LIBOR?

The London Interbank Offered Rate (LIBOR) is a reference rate, and over time since the 1980s has become the dominant rate for most adjustable-rate financial products. A group of banks (panel banks) voluntarily report the estimated transaction cost for unsecured bank-to-bank borrowing terms ranging from overnight to one year for various currencies. The number of currencies and maturities has fluctuated over time, but LIBOR is currently produced across seven maturities: overnight/spot, one week, one month, two months, three months, six months and one year. LIBOR rates are produced for the American dollar, the British pound sterling, the European euro, Japanese yen, and the Swiss Franc, resulting in the current 35 rates.[1][2] The aggregated calculations behind the rates are supposed to reflect the average of what banks believe they would have to pay to borrow currency or the cost of funds for a specified period. However, because the contributions are voluntary, and the rates submitted are a subjective assessment of probable cost, LIBOR indices do not reflect actual transactions.

LIBOR rates became heavily used in trading in the 1980s, officially launched by the British Bankers Association (BBA) in 1986 and regulated by the Financial Conduct Authority (FCA), the independent UK body that regulates financial firms, since April 2013.[3] Until 2014, LIBOR was developed by a group of UK banks, under the BBA. The Intercontinental Exchange Benchmark Administration (ICE) took over administration of the rate in 2014 in an effort to give the rate credible internal governance and oversight – ICE created third-party oversight, which resolved the BBA’s inherent conflict of interest in generating a sound rate while also protecting its member institutions.

Chapter 2
Why is LIBOR changing?

International investigations into LIBOR began in 2012 and revealed widespread efforts to manipulate the rates for profit, with issues discovered as far back as 2003. The investigations resulted in billions of dollars in fines for involved banks globally and jail time for some traders. Most recently, in October 2018, a Deutsche Bank trading supervisor and derivatives trader were convicted of conspiracy and wire fraud in relation to LIBOR rigging.[4]

The scandal challenged the validity of LIBOR and deterred panel banks from continuing their involvement in LIBOR generation. Because LIBOR rates are collected by voluntary contribution, in recent years the number of banks contributing, and therefore also the number of underlying transactions, are waning. In July 2017, Andrew Bailey, Chief Executive of the FCA announced that LIBOR rates would only be formally sustained by the FCA through the end of 2021, due to limited market activity around LIBOR benchmarks and the waning contributions of panel banks. The FCA has negotiated with current panel banks for their agreement to continue contributing data towards LIBOR rate generation through the end of 2021.[5]

Even without the challenge of collecting contributions from panel banks, many regulators have expressed concerns with the representative scale of LIBOR, which creates concerns of instability. The market of products referencing LIBOR dwarfs the transactions that LIBOR is supposed to represent. The New York Fed approximated that underlying transaction volumes for USD LIBOR range from $250 million to $500 million, while exposure for USD LIBOR as of the end of 2016 was nearly $200 trillion.[6]

Chapter 3
What are regulators proposing is the solution?

Talk Scope

In 2014, the Board of Governors of the Federal Reserve System and the Federal Reserve Bank of New York (New York Fed) convened the Alternative Reference Rates Committee (ARRC) in order to identify best practices for alternative reference rates and contract robustness, develop an adoption plan, and create an implementation plan with metrics of success and a timeline. The Committee was created in the wake of the LIBOR scandals, with the intention of verifying some alternatives, though no formal change in LIBOR was announced until 2017. The Federal Reserve reconstituted this board to include a broader set of market participants in March 2018 with the updated objective of developing a transition plan away from LIBOR and providing guidance on how affected parties can address risks in legacy contracts language that reference LIBOR.

In June 2017, the ARRC announced the Secure Overnight Financing Rate (SOFR) as its recommended alternative rate, and the New York Fed began publishing the rate on April 3, 2018. In October 2017, the ARRC adopted a “Paced Transition Plan” with specific steps and timelines designed to encourage use of its recommended rate.[7]

Chapter 4
What is SOFR?

The Secured Overnight Financing Rate (SOFR) is a broad measure of the cost of borrowing cash overnight collateralized by U.S. Treasury securities. As such, it will reflect an economic cost of lending and borrowing relevant to the wide array of market participants active in the financial markets. However, SOFR is fundamentally different from LIBOR. SOFR is an overnight, secured, nearly risk-free rate, while LIBOR is an unsecured rate published at several different maturities. It is a fully transaction-based rate incorporating data from transactions across three segments of the U.S. Treasury Repo market (tri-party repo, General Collateral Finance (GCF) repo and bilateral repo cleared through the Fixed Income Clearing Corporation (FICC)).[8]

The ARRC noted the need for replacement rate spreads due to the differences between rates:

Because LIBOR is unsecured and therefore includes an element of bank credit risk, it is likely to be higher than SOFR and prone to widen when there is severe credit market stress. In contrast, because SOFR is secured and nearly risk-free, it is expected to be lower than LIBOR and may stay flat (or potentially even tighten) in periods of severe credit stress. Market participants are considering certain adjustments, referenced in the fallback proposal as the applicable ‘Replacement Benchmark Spread’, which would be intended to mitigate some of the differences between LIBOR and SOFR.[9]

While the ARRC selection of SOFR as the U.S. replacement rate of choice is final, their selection is only a recommendation that LIBOR be replaced with SOFR. This creates a precarious outlook for the transition: financial institutions have to choose to take the transition seriously, and if they choose to employ rates other than SOFR, the transition could be longer and more complicated than many expect. That said, the cost benefit of choosing a different alternative reference rate is increasingly difficult to justify. With the selection of SOFR as the recommended rate, the New York Fed established an industry standard and did so in a lengthy process that included market participants and a public comment period. They also began publishing SOFR regularly on April 3, 2018.[10]

Additional steps taken by government–sponsored enterprises (GSEs) have initiated the momentum in building out the SOFR market. In July 2018, Fannie Mae issued the first SOFR-denominated securities, leading the way for other institutions who have since followed suit.  In November 2018, the Federal Home Loan Banks (FHLBs) issued $4bn in debt tied to SOFR. The action was taken to support liquidity and help demonstrate SOFR demand to develop the SOFR market for the approximately 7,000 member institutions – banks, credit unions, and insurers – who are in the process of transitioning away from LIBOR.[11] CME Group, a derivatives and futures exchange company, launched 3-month and 1-month SOFR futures contracts in 2018.[12] All of these steps taken to build out the market create a strong start for a rate that is already more stable than LIBOR—the transaction volume underpinning SOFR rates is around $750 billon daily, compared to USD LIBOR’s estimated $500 million.[13]

The ARRC has begun publishing guidance for fallback language and in the fall of 2018 published consultations on recommended language for floating rate notes and syndicated business loans.[14][15]

These initial steps to build out the necessary SOFR market put the United States ahead of the ARRC transition plan schedule and position the market well to begin SOFR implementation. However, a successful transition will require extensive engagement from other institutions. Affected institutions need to begin their transition now in order to make the gradual transition in time for the 2021 deadline.

Chapter 5
Who does this transition affect?

Talk Scope

The transition affects any institutions that hold contracts, products, or tools that reference LIBOR and will not reach full maturity or phase out before the end of 2021. 

 

WHAT ACTIONS DO AFFECTED INSTITUTIONS NEED TO TAKE?

  1. Establish a Sponsor and Project Team:  Affected institutions need to take a phased approach to the transition away from LIBOR. Because of the need for continuous oversight, they should begin by identifying an executive sponsor and establishing a project team. The team should be responsible for all transition-related activities across the organization, including assessment of exposure and the applicability of alternative reference rates where necessary, planning the steps and timing of transition, and coordinating the implementation of transition away from LIBOR.
  2. Conduct an Impact Assessment:  The first task of the project team is to complete an impact assessment to determine the institution’s LIBOR exposure across all financial products and existing contracts that mature after 2021, as well as any related models and business processes (including third-party vendors and data providers). Regarding contracts, the team should identify and categorize all variants of legacy fallback language in existing contracts. Additionally, the assessment should analyze the risk of the LIBOR transition to the institution’s basis and operational risk and across financial holdings.
  3. Mitigate Risks:  Using results from the LIBOR exposure assessment, the project team should develop a plan running through 2021 to prioritize transition activities in a way that best mitigates risk on LIBOR exposure, and communicates the transition activities to employees and clients with ample time for them to learn about and buy into the transition objectives.  
  4. Prepare new products and tools linked to alternative reference rates: This mitigates risk by limiting the number of legacy exposures that will still be in effect in 2021 and creates a clear direction for transition activities. New references may include financial instruments and products, contract language, models, pricing, risk, operational and technological processes and applications to support the new rates.
  5. Develop and Implement Transition Contract Terms: In legacy contracts that will mature after 2021, the project team will need to amend contracts and fallback language. The ARRC has begun to provide guidance for amendments or transitions related to some financial products and will continue to publish legacy transition guidance as it fulfills its mandate. Where necessary, products must move to ARRs.
  6. Update Business Processes: Based on the impact assessment, various business processes surrounding the management of interest rate changes, including those built into models and systems will require updating to accommodate the switch away from LIBOR. For new products utilizing the new index rate, procedures, processes and policies will need to be established and tested before rollout to clients. 
  7. Manage Change and Communicate:  The project team will need to develop educational materials explaining specific changes and their impacts to stakeholders. The materials must be distributed as part of an outreach strategy to external stakeholders, including clients and investors, as well as rating agencies and regulatory bodies. The outreach strategy should help to ensure that the transition message is consistent and clear as it is communicated from executives and board members to operational personnel, other stakeholders and outer spheres of influence.  
  8. Test: Financial institutions will want to prepare for regulatory oversight by testing business processes in advance. Regulators may look for documentation of the processes used to identify and remediate LIBOR risks and any risk exposure that has not been completed.

Chapter 6
Resources

Alternative reference Rates Committee. “Frequently Asked Questions.” Federal Reserve Bank of New York. 20 September 2018. https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-Sept-20-2018-FAQ.pdf, Accessed November 2018.

Bloomberg. “SOFR’s growing use means it’s when, not if, it replaces LIBOR.” 15 October 2018. https://www.bloomberg.com/professional/blog/sofrs-growing-use-means-not-replaces-libor/, Accessed November 2018.

Bloomberg. “The long hunt of an incorruptible successor to LIBOR.” 17 October 2018. https://www.bloomberg.com/professional/blog/long-hunt-incorruptible-successor-libor-quicktake/, Accessed November 2018.

Bloomberg. “America’s LIBOR successor is racing to gain traction.” 11 October 2018. https://www.bloomberg.com/professional/blog/americas-libor-successor-racing-gain-traction/, Accessed November 2018.

Exchanges at Goldman Sachs. “Episode 107: LIBOR’s Long Goodbye.” 29 October 2018. https://www.goldmansachs.com/insights/podcasts/episodes/10-29-2018-granet-and-hammack.html, Accessed November 2018

LSTA. “LIBOR Replacement: Understanding the ARRC’s Loan Fallback Consultation.” 4 October 2018. https://event.webcasts.com/viewer/event.jsp?ei=1214424&tp_key=8e9f891c9a, Accessed November 2018.

McBride, James. “Understanding the LIBOR Scandal.” Council on Foreign Relations. 12 October 2016. https://www.cfr.org/backgrounder/understanding-libor-scandal, Accessed November 2018.

SIFMA Podcast. “The Transition from LIBOR.” 31 October 2018.

ENDNOTES

1 Kiff, John. “Back to Basics: What is LIBOR?” International Monetary Fund. Accessed November 2018. December 2012. https://www.imf.org/external/pubs/ft/fandd/2012/12/basics.htm, Accessed November 2018.

2 “LIBOR – current LIBOR interest rates.” Global Rates. https://www.global-rates.com/interest-rates/libor/libor.aspx, Accessed November 2018.

3 Bailey, Andrew. “The Future of LIBOR.” Financial Conduct Authority. 27 July 2017. https://www.fca.org.uk/news/speeches/the-future-of-libor, Accessed November 2018

4 “Two Former Deutsche Bank Traders Convicted for Role in Scheme to Manipulate a Critical Global Benchmark Interest Rate.” U.S. Department of Justice press release. 17 October 2018. https://www.justice.gov/opa/pr/two-former-deutsche-bank-traders-convicted-role-scheme-manipulate-critical-global-benchmark, Accessed November 2018.

5 Bailey, Andrew. “The Future of LIBOR.” Financial Conduct Authority. 27 July 2017. https://www.fca.org.uk/news/speeches/the-future-of-libor, Accessed November 2018.

6 Alternative Reference Rates Committee. “Second Report.” Federal Reserve Bank of New York. March 2018. https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-Second-report, Accessed November 2018.

7 Alternative Reference Rates Committee. Federal Reserve Bank of New York. https://www.newyorkfed.org/arrc/index.html, Accessed November 2018.

8 Federal Reserve Bank of New York. “Secured Overnight Financing Rate Data.” https://apps.newyorkfed.org/markets/autorates/sofr, Accessed November 2018.

9 Federal Reserve Bank of New York. “ARRC Consultation: Regarding more robust LIBOR fallback contract language for new originations of LIBOR syndicated business loans,” 24 September 2018. https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-Syndicated-Business-Loans-Consultation.pdf, Accessed November 2018.

10 Federal Reserve Bank of New York. “Statement Introducing the Treasury Repo Reference Rates,” 3 April 2018. https://www.newyorkfed.org/markets/opolicy/operating_policy_180403, Accessed November 2018.

11Guida, Victoria. “Federal Home Loan Banks boost LIBOR replacement with $4B debt issuance,” Politico. 13 November 2018. https://www.politico.com/story/2018/11/13/federal-home-loan-banks-libor-replacement-939489, Accessed November 2018.

12 CME Group. “Secured Overnight Financing Rate (SOFR) Futures.” https://www.cmegroup.com/trading/interest-rates/secured-overnight-financing-rate-futures.html, Accessed November 2018.

13 Graph: LSTA. “LIBOR and the Loan Market.” 24 April 2018. https://www.lsta.org/uploads/DocumentModel/3523/file/libor-in-the-loan-market_042418.pdf, Accessed November 2018.

14 Federal Reserve Bank of New York. “ARRC Consultation: Regarding more robust LIBOR fallback contract language for new issuances of LIBOR floating rate notes,” 24 September 2018. https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-FRN-Consultation.pdf, Accessed November 2018.

15 Federal Reserve Bank of New York. “ARRC Consultation: Regarding more robust LIBOR fallback contract language for new originations of LIBOR syndicated business loans,” 24 September 2018. https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-Syndicated-Business-Loans-Consultation.pdf, Accessed November 2018.

16 Federal Reserve Bank of New York. “Minutes,” Alternative Reference Rates Committee (ARRC). 31 October 2017. https://www.newyorkfed.org/medialibrary/microsites/arrc/files/2017/October-31-2017-ARRC-minutes.pdf, Accessed November 2018.

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