The Beginning of the End of the End: Transitioning Loans and Derivatives from USD LIBOR in 2021
Client Alert | 1 min read | 03.10.21
On March 5, the UK’s Financial Conduct Authority announced the dates on which USD and other LIBOR settings will cease to be published, officially marking the long-anticipated beginning of the end of a multi-year process to terminate LIBOR and transition markets to new benchmark rates.
In this client alert, Julia Lu and John A. Clark compare model USD LIBOR fallback approaches that have been promulgated by policymakers and industry leaders in the U.S. syndicated loan market, on the one hand, and the over-the-counter derivatives market, on the other, and discuss two alternative strategies for market participants seeking to minimize basis risk arising from different fallback approaches.
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Client Alert | 10 min read | 03.27.25
FinCEN Axes Corporate Transparency Act’s Reporting Obligations for U.S. Companies and U.S. Persons
Since December of last year, the status of the CTA has been in a state of perpetual flux, following a dizzying series of federal court rulings and FinCEN announcements. On February 28, 2025, we reported that FinCEN paused enforcement actions for entities required to report under the CTA’s Beneficial Ownership Information Reporting Rule (BOI Rule) until FinCEN issued an interim final rule providing new guidance regarding the BOI Rule’s requirements and associated deadlines. Then, on March 2, 2025, Treasury went a step further, indicating that it would altogether cease enforcement against U.S. citizens and domestic reporting companies for violations of the BOI Rule, explaining that it would instead issue proposed rulemaking to narrow the scope of the BOI Rule to “foreign reporting companies” only and set new reporting deadlines.
Client Alert | 3 min read | 03.27.25
Client Alert | 3 min read | 03.27.25
MoCRA Under the Trump Era: A Look at FDA's Monitoring and Enforcement Two Months In
Client Alert | 4 min read | 03.27.25
