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©2023 International Swaps and Derivatives Association, Inc.
ISDA® is a registered trademark of the International Swaps and Derivatives Association, Inc.
Relevant Provisions in the 2006 ISDA Definitions and 2021 ISDA
Interest Rate Derivatives Definitions
USD LIBOR FROs
Contain SOFR-based
fallbacks published by SOFR FROs
Bloomberg
(provided entered on or after January 25,
2021 or amended by the 2020 IBOR
Fallbacks Prtocol)
Compounding and
Index Compounding Averaging Provisions
Provisions
A = Determination of compound rate; B = Annualizing factor; C = Day count adjustment between USD LIBOR and SOFR (in this case both use Act/360 so the factor is 1)
• Step 6 – Add the Spread Adjustment of 0.26161% for the 3M Tenor to determine the Fallback Rate for the Original Rate Record Date of Thursday
13th April 2023
• The Payment Date will be specified in the contract and will typically be at the end of the relevant Calculation Period.
• Parties can define the relevant Business Days in the contract so as to ensure that the Fallback Rate will be known two days in advance of the
payment being due based on the Business Day calendar in relevant jurisdictions.
• If the parties do not specify places for the purposes of the reference to Business Days for payment purposes within the contract, then the ISDA
Definitions will implement default Business Day calendars (e.g. London for GBP LIBOR).
• This means that two transactions which referenced the same IBOR on the same day may apply a different Fallback Rate if different Business Day
calendars apply to those transactions.
• If the Fallback Rate for the Original IBOR Rate Record Day corresponding to the Reset Date (or the day two banking days prior to the Reset
Date, as applicable) is not produced by Bloomberg two Business Days prior to the Payment Date, then the Fallback Rate that has been
published for the most recent Original IBOR Rate Record Day should be used.
• This will have the effect of applying a dynamic ‘backward shift’ (i.e. the standard two-day backward shift that applies under the Bloomberg Rule
Book for the Fallback Rates will effectively be lengthened in this scenario to the number of days necessary for the Fallback Rate to be known two
Business Days prior to the ‘Payment Date’).
• This mechanism is also important for stub periods for which linear interpolation is not specified and for certain non-linear transactions (including
those for which the Payment Date is not at the end of the relevant IBOR period).
• SOFR values are published on the Business Day following their value date, i.e., T+1
• For USD LIBOR Fallbacks, the IBOR Value Lag (or Spot Lag) is two LIBOR Business Days for each USD LIBOR tenor except the overnight tenor, for
which the IBOR Value Lag is zero
• Each calculation, being the Adjusted RFR, the Spread Adjustment and the ‘all-in’ Fallback rate is rounded to the rounding precision noted in the
methodology Rulebook: 5dp in the case of USD LIBOR Fallback calculations
• Fallback rates are published for every Rate Record Date, regardless of whether such date was a business day
• Non-publication of SOFR on a ‘good business day’, including under SIFMA definitions Friday 7th April 2023 which was effectively a ‘half-day’ for US
government securities trading, will be treated as a Market Disruption Event and consequently a non-business day for the purpose of fallback
calculations
• USD LIBOR Fallback Rates are not ‘new benchmarks’ under Benchmark Regulation; the benchmarks remain USD LIBOR and SOFR
SOFR Futures and Options (F&O) franchise in 2023 YTD is surpassing the four-decade history of Eurodollar
F&O franchise, with volumes exceeding the best years ever seen in Eurodollars by:
• +33% for SOFR Futures, with 2023 YTD ADV of 4.0M contracts
• +50% for SOFR Options, with 2023 YTD ADV of 2.5M contracts
ADV: Average Daily Volume
Source: CME Group
OI: Open Interest (open positions)
3-Month
SOFR futures
* Final settlement price of Eurodollars will be to 4 decimal places to conform with existing client infrastructure, with the impact of the additional 0.001bp being handled by a
balancing cash flow between longs and shorts (cash residual amount)
3-Month
SOFR options
* Premium differential corresponds to premium differences between ED Option premium corresponding to Strike K vs. SR3 Option premium corresponding to Strike (K + 25 bps)
Important Reminders:
• Customers are strongly encouraged to complete trading needs in Eurodollars by April 13 th, given clearing time restrictions on April
14th for impacted contracts
• Early exercise will be prohibited on April 14th. Pit Out-Trades, Unclaimed Transfers, and Unclaimed Allocations (Give-ups, Average
Priced Allocations) will be deleted from FECPlus prior to the EOD Cycle for all conversion-eligible contracts (Clearing Advisory)
• Exchange transaction fees will be waived for transfers in connection with conversion (SER).
• Following conversion, only April, May, and June 2023 Eurodollar futures and options will remain listed.
• If you still use Eurodollar data for curve construction, valuation, or pricing purposes, it is imperative that you switch to SOFR ahead
of April 14 to avoid disruptions.
Conversion Resources:
• Eurodollar Fallbacks Implementation Plan - Our complete guide to the conversion process
• Indicative Cash Flow Report - See how position quantities for Eurodollars would be converted to corresponding SOFR positions,
as well as the cash flows for each.
• Contact Information: Inquiries can be directed to our team at ListedConversionInquiries@cmegroup.com
January 2023
“LCH plan to convert Outstanding USD LIBOR Contracts into Market-Standard SOFR OIS equivalents
on a cash-compensated basis in mandatory events conducted shortly before USD LIBOR cessation”
Outstanding USD LIBOR Contracts All LCH-cleared USD LIBOR swap contracts which are outstanding on the Conversion Dates and which rely on at least one LIBOR setting beyond
30th June 2023 will be subject to conversion
Market-standard SOFR OIS The contracts generated by the conversion process will carry a market-standard SOFR floating leg in which LIBOR will be replaced by
standardised backward-looking compounded SOFR and to which the relevant IBOR Fallbacks Spread Adjustment will be added (see table below).
The terms of any non-LIBOR leg on the original contract will be unchanged
Conversion Dates Tranche 1 Date: 22nd / 23rd April 2023 Tranche 2 Date: 20th / 21st May 2023
Products in scope Tranche 1 Products: VNS, ZCS Tranche 2 Products: All other USD LIBOR-based products
Representative LIBOR Continuity To minimise disruption, LCH aim to preserve the cashflows associated with representative USD LIBOR settings via overlay bookings
Cash Compensation LCH will cash compensate for any valuation difference between the original LIBOR trade and the SOFR contract (including overlays)
Process Mechanics LCH expect to characterise the process legally as a trade amendment; operationally, trades will be terminated and rebooked
Process Fees Applicable Fallback Fees and Conversion Fees are available here: Rates Reform: USD LIBOR Fallback and Conversion Fees | LCH Group
Back-stop LCH’s conversion process should be treated as a back-stop. Market participants are strongly encouraged to convert pro-actively
LCH’s conversion processes and dress rehearsals will happen over the weekend and will be based on the contract population on the
Friday’s EOD close immediately prior to the weekend, according to the schedule below.
Date Event
Monday 31st October 2022 • Unilateral Basis Swap Splitting Tool and eligibility enhancements available in Member Test*
Monday 12th December 2022 USD LIBOR Conversion Tools and Reports available in production
• Unilateral Basis Swap Splitting Tool
• REP000315; REP00072FB
• Eligibility Enhancements
• Indicative Conversion Tools via Portal
Friday 24th February 2023 Dress rehearsal #1: Tranche 1 and 2 products
Friday 31st March 2023 Dress rehearsal #2: Tranche 1 and 2 products (SGD DR will also take place on this date)
Friday 19th May 2023 Contingency Production: Tranche 1 USD LIBOR Conversion
Friday 2nd June 2023 Contingency Production: Tranche 2 USD LIBOR Conversion
Friday 9th June 2023 Production: SGD SOR Conversion & THB THBFIX Conversion
*REP315 and indicative conversion tools were released directly into production on 12 December.
Following conversion, LCH will withdraw USD LIBOR eligibility (products with no LIBOR leg are not affected). We will however continue to
support trade registration between the Conversion Events and USD LIBOR cessation date (30th June 2023) via the following arrangements:
Product From Monday 24th April From Monday 22nd May Alternative Booking Solution
until COB Friday 19th May until COB Friday 30th June
IRS Eligible Eligible* (Legacy) Not required
VNS Eligible Eligible* (Legacy) Not required
ZCS Ineligible Ineligible None
Basis (LIBOR/SOFR) Eligible Alternative Booking Solution * LIBOR/Fixed (IRS)* + Fixed/SOFR (SOFR OIS)
Basis (LIBOR/LIBOR) Eligible Alternative Booking Solution * LIBOR1/Fixed (IRS)* + Fixed/LIBOR2 (IRS)*
Basis (LIBOR/FedFunds) Eligible Alternative Booking Solution * LIBOR/SOFR (Basis)* + SOFR/FedFunds (Basis)
* On Monday 22nd May 23, after Tranche 2 conversion, LCH’s USD Legacy solution will go live. Under this solution, eligible USD IRS &
VNS products (reduced scope relative to current eligibility†) can be registered and will undergo an intra-day conversion into SOFR
equivalents as summarised below:
What happens to eligible Legacy LIBOR trades upon registration? Which products are eligible?
After registration of the USD LIBOR trades but before EOD, LCH will convert each Plain vanilla IRS and VNS are eligible.
Legacy LIBOR trade to a SOFR equivalent contract using the same conversion Periodic compounding IRS, ZCS and Basis swaps are not
methodology deployed in the Conversion Events but without overlays. LCH will supported. IRS and VNS trades with stub periods and/or other
also calculate and settle cash compensation associated with this daily conversion. non-generic features are also not supported†.
† A product matrix detailing the full clearing eligibility for USD Legacy LIBOR can be found on LCH Knowledge Centre: Document Library (force.com). Further details around SwapClear
USD Legacy solution are available in LCH Circular No 4235.
• This document has been provided to you for informational purposes only and is intended as an overview of certain aspects of or proposed changes to the ForexClear service provided by LCH
Group Holdings Limited (“LCH Group”) or any of its group undertakings (group undertakings shall be construed in accordance with section 1161 of the Companies Act 2006; each an “LCH Group
Company”). LCH Limited (“LCH”) is regulated as a “recognised central counterparty” authorised under Regulation (EU) No. 648/2012 of the European Parliament and of the Council of 4 July 2012
on OTC derivatives, central counterparties and trade repositories and supervised by the Bank of England within the UK regulatory framework, and is a “derivatives clearing organization”
registered with the U.S. Commodity Futures Trading Commission.
• The relationship of an LCH Group Company with its members is governed solely by its rulebook and certain other ancillary documentation, as applicable. This document does not, and does not
purport to, contain a detailed description of any aspect of a service provided by an LCH Group Company or any other topics discussed in this document, and it has not been prepared for any
specific person. This document does not, and does not seek to, constitute advice of any nature. You may not rely upon the contents of this document under any circumstance and should seek
your own independent legal, investment, tax and other advice. The information and any opinion contained in this document does not constitute a recommendation or offer with respect to any
derivative contract, financial instrument, security or service. No LCH Group Company makes any representation, warranty, condition or guarantee (whether express or implied) that the contents
of this document are accurate, complete or up-to-date, and makes no commitment to offer any particular product or service. No LCH Group Company shall have any liability for any losses, claims,
demands, actions, proceedings, damages, costs or expenses arising out of, or in any way connected with, the information contained in this document, except that each LCH Group Company
accepts liability that cannot be excluded by applicable law.
• Copyright © LCH Limited 2023. All rights reserved. ForexClear is a registered trademark of LCH.
• The information contained in this document is confidential. By reading this document, each recipient agrees to treat it in a confidential manner and will not, directly or indirectly, disclose or
permit the disclosure of any information in this document to any other person (other than its regulators or professional advisers who have been informed of the confidential nature of the
information) without the prior written consent of LCH Group.
Dress Rehearsal 1 – Basis Swap Splitting – Jan 27 Basis Swap Splitting – Mar 24
• New Release test to split LIBOR-LIBOR & LIBOR-SOFR to fixed-float swaps • Production splitting of LIBOR-LIBOR & LIBOR-SOFR to fixed-float swaps
1% 1%
1%
Conv 7/15/23 10/15/23 … 4/15/24
Conv 7/15/23 10/15/23 … 4/15/24
4/15/23 4/15/23
3M LIBOR 3M LIBOR 3M LIBOR
3M LIBOR
Conversion Conversion
Short LIBOR Replacement Forward SOFR Replacement* Short LIBOR Replacement Forward SOFR Replacement*
3M LIBOR vs 1% IRS SOFR vs 1% OIS 3M LIBOR vs 1% IRS: SOFR vs 1% OIS
Start= 4/15/23; Maturity= 7/15/23 Start= 7/15/23; Maturity= 4/15/24 Start= 4/15/23; Maturity = 7/15/23 Start= 7/15/23; Maturity = 4/15/24
Fixed Pays 3m, Float Rec 3m Fixed Pays 3m, Float Rec 3m Fixed Pays 3m, Float Rec 3m Fixed Pays 6m, Float Rec 3m
1% 1% 1T 1% Stub 1%
Conv 7/15/23 10/15/23 … 4/15/24 Conv 7/15/23 10/15/23 … 4/15/24
4/15/23 4/15/23
3M LIBOR SOFR + SOFR +
3M LIBOR
Spread Spread
*Forward SOFR Replacement swap will default to a 2D payment offset on both the fixed and floating legs
*Cash compensation settled on Apr 24th in form of upfront fee on SOFR OIS Replacement
• CFTC Rulebook Filing – January 2023 filing with the CFTC that details CME Group’s conversion plan for cleared USD LIBOR
swaps
• Detailed Conversion Plan – CME Group’s public presentation and complete overview of the cleared USD LIBOR swap
conversion
• Conversion Videos – Series of four high-level videos that discuss the cleared USD LIBOR swap conversion
• Contact Information: Inquiries can be directed to our team at ClearedSwapConversion@cmegroup.com
ISDA Webinar
12 April 2023
Eurex – OTC Cleared Market Conversion of USD LIBOR
Key Dates OTC Cleared market transition of USD Libor
❖ Eurex Clearing will preserve and employ the identical approach for
• SOD - Post-Trade Events for USD denominated trades
USD LIBOR conversion as it did for previous LIBOR conversions:
21st April 2023 will not be permitted
➢ Limited eligibility of USD FRAs ahead of conversion
• Last day for USD LIBOR swaps to be clearing eligible
• Maximum maturity 31st March 2023
Date of Conversion for USD LIBOR Swaps1 ➢ Active conversion of all outstanding USD LIBOR IRS by replacing
• Cleared USD LIBOR swaps will be terminated contractual reference of LIBOR with SOFR
• Amended trades will be novated, with compensation ➢ LIBOR fixings and settlements known before cessation will be
22nd April 2023
fees attached conserved and processed by means of a pair of short maturity overlay
• Terminated and new trades will be synchronized with swaps
MarkitWire – Netting Synchronisation2 ➢ LIBOR-LIBOR basis swaps will be shortened (no basis swap splitting)
The amended trades will be employed in the margining ➢ Resulting PV differences to today mitigated by adding the ISDA/BBG
24th April 2023
and valuation processes (SOD) fallback spread and cash compensation
• The compensation fee per converted trade will be ➢ No forced compression or additional fees
settled in the form of an upfront fee or a termination fee
25th April 2023 ❖ The conversion approach that will be prevalently employed
• Capacity to execute Post-Trade Events for USD
denominated trades will be reinstated ➢ All LIBOR fixings and settlements are known prior to the index cessation
date for the current floating period
R1. A full maturity RfR OIS trade with identical start and maturity dates as the
original LIBOR trade
R2. A short maturity (known LIBOR fixings) LIBOR IRS trade identical to the
1. USD LIBOR swaps with a floating leg in the final period and a final LIBOR fixing prior to index cessation original LIBOR IRS trade
will not be converted R3. An opposite short maturity replacement RfR OIS trade with identical start
2. For trades originally received from MarkitWire and members having Netting synchronisation enabled
and end dates as R2
Eurex Clearing AG
Mergenthalerallee 61
65760 Eschborn
Tel: +49 (0) 15120976888
aditya.dhadam@eurex.com
Fallback Data Availability
Data Publication
• Bloomberg began publishing fallback data on July 17, 2020
• Data is calculated and published every weekday for USD LIBOR fallbacks and for each of the 18 other rate sets. This includes the Adjusted
Reference Rates, Spread Adjustments and ‘all-in’ Fallback rates, subject to holiday calendars
• For USD LIBOR fallbacks, the latest data is normally published shortly after the publication of the latest SOFR (published at 8am ET). Similarly for
the other fallback rates, data is typically published within 30 - 45 minutes of the official publication time of the relevant RFR
Distribution Channels
• Bloomberg Terminal
• Bloomberg Data License & B-Pipe data feed
• Bloomberg website, on a 24hr delay, with a rolling five-day history file
• Authorized re-distributors
ISDA Protocols
Benchmark Transition Hub
ISDA 2021 Definitions
ISDA – Clarus RFR Adoption Index
ISDA-Brattle Microsite