On March 9, 2021, the Federal Reserve in its Supervision and Regulation Letter (the
Letter) provided guidance to Federal Reserve examiners and supervised institutions to assist in assessing progress in preparing for the LIBOR transition.
Specifically, examiners are directed to review the supervised institutions’ “planning for, and progress in, moving away from LIBOR.” Supervised institutions should note that examiners are encouraged to consider taking supervisory action if an institution is not ready to cease issuances of new LIBOR-based contracts by the end of 2021.
In the Letter, the Fed recognizes that the transition plans will differ depending on the institution’s LIBOR exposure and have provided separate guidance for those with less than $100 billion in total consolidated assets (