Now is the time for financial services firms to prepare for interest rate benchmark reforms

The replacement of the Interbank Offered Rates (IBORs) will have a major impact on financial services firms around the world, and regulatory agencies are pressuring institutions to begin their transitions
August 9, 2019 - Editor
Category: Regulation

The replacement of the Interbank Offered Rates (IBORs) will have a major impact on financial services firms around the world, and regulatory agencies are pressuring institutions to begin their transitions to alternate or reformed benchmark rates ahead of a proposed 2021 deadline.

The replacement of the Interbank Offered Rates (IBORs) will have a major impact on financial services firms around the world, and regulatory agencies are pressuring institutions to begin their transitions to alternate or reformed benchmark rates ahead of a proposed 2021 deadline. Fraud and conspiracy scandals surrounding IBOR manipulations go back as far as the early 1990s, prompting the industry to start considering risk-free reference rates (RFRs). In 2017, the stage was set for a worldwide transition when the United Kingdom’s Financial Conduct Authority (FCA) said that firms need to end their reliance on and begin moving away from the London Interbank Offered Rate (LIBOR) before the end of 2021.

In a July 3, 2019, letter to the chief executive officers of significant financial institutions, the European Central Bank emphasized that a clear understanding of the risks associated with global benchmark reform is needed for a successful transition. The central bank appears concerned about the ability of financial institutions to meet all the regulatory requirements by the end of 2021.

Similarly, on July 12, the U.S. Securities and Exchange Commission (SEC) issued a statement on LIBOR transition, while the United Kingdom’s FCA LIBOR transition briefing to chief executive officers on July 15 added another layer to the warnings. The statements highlight potential transition risks and provide guidance on related disclosure obligations and risk management efforts related to the discontinuation of current interest rate benchmarks.

Deadlines coming

LIBOR (and its equivalent global indexes) have been the reference rate for the financial industry for more than 40 years — $350 trillion in financial products are LIBOR-indexed. The transition to alternative risk-free rates will come with a vast number of challenges for financial institutions that must comply with several deadlines determined by the regulators.

In terms of the new risk-free rates, it has been reported that by the fourth quarter of 2019, the daily publication for the Euro short-term rate (€STR) is expected, as is the transition to €STR from the Euro OverNight Index Average (EONIA), which is the one-day interbank interest rate for the Euro zone. €STR is an interbank interest rate calculated by the European Central Bank on the basis of unsecured loans contracted overnight between financial institutions. By the third quarter, the Sterling Overnight Index Average (SONIA) transition will begin, and fallback plans will be implemented, according to reports. SONIA is based on actual transactions and reflects the average of the interest rates that banks pay to borrow sterling overnight from other financial institutions.

In the first half of 2020, the Federal Reserve Bank of New York will begin publishing a series of backward-looking secured overnight financing rates (SOFR) and is expected to publish a forward-looking term SOFR rate by the end of 2021. SOFR is an influential interest rate that banks use to price U.S. dollar-denominated derivatives and loans. By the third quarter, LIBOR production will no longer be guaranteed by the United Kingdom’s FCA, and by Jan 1, 2022, EU Benchmarks Regulation (BMR) compliance will be required for all European Union users and administrators of European and third-country benchmark rates.

Expect cross-functional disruption

IBOR transition represents a major cross-functional undertaking for all global financial institutions. It is important for financial markets participants not to delay the completion of an IBOR transition impact assessment for their front-to-back value chain. DXC Technology has compiled a high-level view of IBOR impacts across organizations, as shown in Figure 1.


Main Impacts

Indicative Level of Impact

Business/Front Office

  • In-scope trade inventories, conversion approaches, unwinding/terminating open trades
  • Valuation process and hedging strategies
  • IBOR product development to maintain the product offering, including development of new ARR trades and negotiation of related spreads
  • Modeling/estimating the business impact of transition (i.e., P&L and risk profiling)
  • Client outreach strategy



  • Adjustment of collateral management (initial margin (IM)/variation margin (VM)), confirmation templates
  • Multiple processes, controls and user tools with IBOR references




  • Market data acquisition and time series building (Fundamental Review of the Trading Book (FRTB))
  • Impact on pricing and risk management models, new risk factors, risk methodology amendments
  • Difficulties to hedge open positions, using the same strategy, or at the same costs
  • Important basis risk between the current and new reference rates during the transition period



  • Identification of contracts that refer to IBOR rates — to be modified, retained or canceled
  • Review and modification of existing contracts: e.g., payment clause, penalty clause, fixing and reset clauses, fallbacks
  • Legacy contract amendments, e.g., International Swaps and Derivatives Association (ISDA), Credit Support Annex (CSA), Global Master Repurchase Agreement (GMRA), Global Master Securities Lending Agreement (GMSLA), etc.



  • Variable rate debt will force companies to switch to an effective exchange rate, which could affect key ratios
  • Lack of sustainable liquidity in the market
  • Amendments to intergroup funding structures


IT & Data

  • Front-to-back analysis of reference rate creation
  • System impact assessment and mapping (trade capture/booking systems, risk management, settlement, accounting, reporting and clearing systems)
  • Implementation and testing within systems
  • Challenges for data sourcing and validation


Tax & Accounting

  • The renegotiation of contracts implies an assessment of tax obligations
  • Policies, procedures and system changes may be required
  • Cash flow hedge accounting
  • Changes to intergroup funding structures that could affect single-entity reserves


Figure 1. IBOR impacts across functions, with 1 being lowest impact and 4 being highest impact

3 key steps to successful transition

Considering all the impact areas and following our analysis of this transition in a specific market context, contract remediation appears to be one of the biggest challenges. Due to the huge volume of documents (many of which are not in digital/machine-readable format) residing in various heterogeneous contract storage systems, contract reviews will represent not only significant operational workloads, but technological challenges as well.

To ensure an efficient transition, financial institutions must make the remediation process efficient, flexible and compliant with local laws. Above all, they must ensure that the process isn’t disruptive to customers. The remediation process can be managed using a combination of business process changes and resource augmentation, and the smartest players will partner with leading technology firms to leverage digital accelerator technologies such as optical character recognition (OCR), robotic process automation (RPA) and artificial intelligence (AI) to speed this process.

A strong change/program management function is paramount. It must consist of a multidisciplinary team to manage the transition from a business, operational, legal and IT perspective. This team should understand how the transition will affect the organization’s operating model. In addition, the development of an independent risk-monitoring framework can strengthen the overall program structure.

Far-reaching change such as this requires a robust end-to-end testing strategy. From market data acquisition to pricing, margin call and risk-monitoring processes, a test factory or center of excellence can ensure that all changes made across an institution’s systems and processes are validated and verified prior to go-live. The testing process will have to be standardized, automated where relevant and fully documented for regulatory audit purposes. The testing factory setup would mix business and function capabilities.

Getting ready for IBOR transition

The European Central Bank’s letter petitioned banks for the following information:

  • A board-approved summary of each institution's assessment of key risks relating to benchmark reform and a detailed plan to:
  • Mitigate such risks
  • Address pricing issues
  • Implement process changes
  • Contact points at the management level to oversee the implementation of these plans

Significant institutions were asked to submit this by July 31, 2019.

Despite the numerous uncertainties relating to IBOR transition, institutions should mobilize quickly to minimize the risks of not meeting the regulatory deadlines in time or staying aligned with their peers. The deadline may be 2 years out, but the time to start transitions is now.

DXC Technology has an end-to-end IBOR transition offering that includes consulting, analytics and information governance, application services, platform implementation, contract remediation and testing services. We leverage digital tooling such as automation and AI to accelerate delivery of your transition programs. Contact us to see how DXC can help you make a successful transition.

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About the authors

Rajesh Sadhwani is a client partner in DXC Technology's Banking and Capital Markets practice in London. He has over 15 years consulting, program management and business development experience working with capital markets firms to structure and deliver global transformation programs to achieve post-merger integration, strategic cost reduction and respond to regulatory changes. Rajesh is passionate about helping capital markets clients navigate the strategic, technological and execution-related challenges and opportunities created by the digital revolution.

Sylvain Collado is partner in DXC Technology’s Banking and Capital Markets practice in Paris. He supports financial institutions in their operating model transformations, which are driven by regulatory constraints and cost requirements.

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