We deeply understand our target market of mid-size and small institutions, and how their needs differ from those of large institutions

Our 5x5 Framework for LIBOR Transition and Conversion: 5-Dimensions x 5-Phases

We take pride in working with clients to help solve their pressing issues and turn challenges into opportunities. To deal with the extra-ordinary complexity posed by the sunset of LIBOR and the replacement with SOFR or Ameribor (in the USA), we created a specialist division at our firm that focuses only on issues resulting from LIBOR Transition and Conversion.  Our LIBOR division brings not only unparalleled industry expertise and experience but also artifacts and solutions to execute our 5x5 framework for LIBOR Transition and Conversion:  Our Services and Solutions executed in    5 phases to resolve impacts to the 5 dimensions of organizations.

Our singular goal is to ensure a complete transformation of the client organization and enable it to thrive in the post-LIBOR world.  Our LIBOR division helps mid-size and small financial institutions to: Fully understand and assess transition risks and impacts across the entire organization; Develop strategic roadmaps with prioritized initiatives and milestones; Cohesively execute transition initiatives by automating intelligently and conversion initiatives by using AI technology. 

Ideally, all financial institutions, intermediaries, and investors would like to move away from LIBOR to SOFR or Ameribor in a swift, stable, and straightforward way. 

However, synchronized execution at the systemic level is practically impossible.  Just imagine the sheer number and variety    of changes that need to be effected across fixed income and derivatives markets, products, systems, and frameworks - for    all market participants, all of whom are subject to the same deadline of Dec 31, 2021.

The complexity to achieve a stable and straightforward transition and conversion is amplified significantly when we consider  all the sequential and cross dependencies between all the market participants (lenders, borrowers, servicers, investors, platforms, exchanges, regulators, etc).

Industry Experts in markets, operations, and governance are visualizing a potential   for disruptions resulting from the Transition and distortions from the Conversion. 


  • LIBOR is embedded within a plethora of financial instruments that may be on-balance-sheet and off-balance-sheet including: FRNs, ARMs, HELOCs, structured debt, student loans, commercial loans, syndicated loans, multifamily loans, lines of credit, contingent capital, auction-rate securities, securitizations, REMICs, CLOs, CDOs, and varieties of complex interest rate derivatives like swaptions.

  • LIBOR affects lenders, customers, software vendors, platforms, and investors of financial products including banks, credit unions, insurance companies, servicers, custodians, money managers, REITs, municipalities, corporations, consumers.

  • LIBOR is the primary driver of all money-market and swap rates, effectively influencing the entire derivatives market.

  • LIBOR is fundamentally different from SOFR or Ameribor in terms of drivers, economics, calculations, valuation, risk, etc.

  • LIBOR to SOFR transition will transform every market participant's risk profile, forecasts, processes, procedures, controls

  • SOFR based business will require changes to products, models, valuation tools, hedging strategies, payment systems etc.

  • Cross-dependencies between lenders/customers/servicers/investors/vendors will create huge operational challenges  

Why are industry experts envisioning the Transition and Conversion to be disruptive?

1. LIBOR is fundamentally different from  SOFR/Ameribor -- conceptually, economically, operationally, behaviorally, legally

2. The move away will transform every market participant's risk profile, forecasts, processes, procedures, controls

3. The move away will require changes to product design, risk models, valuation tools, hedging strategies, payment systems,...

4. Interdependencies between lenders/customers/servicers/investors/vendors will present huge operational challenges  

The enormity of the market size with the vast array of financial instruments/contracts and market participants, with many interdependencies between them, will not allow for an 11th hour transition.

Regulators are very concerned about slow progress at many regulated institutions

 Andrew Bailey, Chief Executive, Financial Conduct Authority

 “And for firms who are not yet aware, not yet engaged, and without plans to address their LIBOR-related   dependencies, I warn you again of the risks.”

 Michael Held, Executive Vice President and General Counsel, Federal Reserve Bank of New York

 “This is a DEFCON 1 litigation event if I’ve ever seen one... a “situation that invites litigation” that “would be     on a massive scale.”

 John C. Williams, President and Chief Executive Officer, Federal Reserve Bank of New York

 “Some say only two things in life are guaranteed: death and taxes. But I say there are actually three: death,   taxes, and the end of LIBOR.”

 Linda Lacewell, Superintendent, NY State Department of Financial Services

 "....the Department requires that each regulated institution submit a response to the Department describing   the institution’s plan to address its LIBOR cessation and transition risk."

 Regulated Financial Institutions need to ask themselves 3 important questions:

 1. Are we INFORMED comprehensively about the risks and impacts of Transition and Conversion to our institution?

 2. Are we STRATEGICALLY prepared to accomplish Transition and Conversion for our institution?

 3. Are we OPERATIONALLY capable to conduct Transition and Conversion at our institution?

                                               For most mid-size and small institutions,

                                          the answer to at least one of these questions

                                                            is going to be, "NO".

Excerpts from the letter (Dec 23, 2019):

"... the Department is issuing this letter to seek assurance that regulated institutions’ boards of directors, or the equivalent governing authorities, and senior management fully understand and have assessed the risks associated with LIBOR cessation, have developed an appropriate plan to manage them and have initiated actions to facilitate transition."  

"As regulated institutions are engaged in credit, derivatives, and securities transactions that are linked to LIBOR, its cessation will have a significant impact on such institutions as well as the broader market."   “It is imperative that regulated financial institutions with LIBOR exposure have robust and comprehensive plans in place to address their risk."  "Inadequate preparation for transition to alternative rates could have an adverse impact on the safety and soundness of regulated institutions and may cause harm to consumers and markets. Such transition requires a significant amount of work, which should have already commenced."

"To that end, the Department requires that each regulated institution submit a response to the Department describing the institution’s plan to address its LIBOR cessation and transition risk."

 Regulated Financial Institutions need to ask themselves 3 important questions:

 1. Are we INFORMED comprehensively about the risks and impacts of Transition and Conversion to our institution?

 2. Are we STRATEGICALLY prepared to accomplish Transition and Conversion for our institution?

 3. Are we OPERATIONALLY capable to conduct Transition and Conversion at our institution?

                                               For most mid-size and small institutions,

                                          the answer to at least one of these questions

                                                            is going to be, "NO".

Worried by the slow progress of many regulated financial institutions, the NY Department of Financial Services (DFS) has asked the Boards, CEOs, CFOs of all financial institutions under its purview to submit their comprehensive plans for LIBOR Transition. 

 Has your institution responded satisfactorily to the NY Department of Financial Services​​ (DFS)

 "Request for assurance of Preparedness for LIBOR Transition" ?

      Abundant risks persist at the macro and micro levels because every financial:

         Product | Agreement | Document | Disclosure | Data | Calculation | Forecast | Valuation

         Model | Operation | Technology | Framework | Platform | Policy | Procedure | Reporting 

  ... linked to LIBOR, directly or indirectly, will require remediation by its sunset at the of 2021

      and earlier if certain triggers are activated.  Interconnections amplify risks and impacts.

To industry experts and the regulators, it is starkly apparent that the move away from LIBOR to SOFR or Ameribor will present a gamut of challenges.  Every financial market player engaged with products or valuations using LIBOR will need to make numerous adaptations.  To achieve a stable transition and fast-track conversion, the "multi-dimensional impacts" will need to be fully understood, assessed, planned, and flawlessly executed in a phased manner.  Institutions will need to evaluate which portions of the Transition and Conversion shall be remediated using internal resources, external specialists and technologies, or a synergetic combination of them.

Excerpts from the letter (Dec 23, 2019):

"... the Department is issuing this letter to seek assurance that regulated institutions’ boards of directors, or the equivalent governing authorities, and senior management fully understand and have assessed the risks associated with LIBOR cessation, have developed an appropriate plan to manage them and have initiated actions to facilitate transition."  

"As regulated institutions are engaged in credit, derivatives, and securities transactions that are linked to LIBOR, its cessation will have a significant impact on such institutions as well as the broader market."   “It is imperative that regulated financial institutions with LIBOR exposure have robust and comprehensive plans in place to address their risk."  "Inadequate preparation for transition to alternative rates could have an adverse impact on the safety and soundness of regulated institutions and may cause harm to consumers and markets. Such transition requires a significant amount of work, which should have already commenced."

"To that end, the Department requires that each regulated institution submit a response to the Department describing the institution’s plan to address its LIBOR cessation and transition risk."

 

Where is your organization in its LIBOR Transition and Conversion Journey?

 

Our 5x5 Framework for LIBOR Transition and Conversion: 5-Dimensions x 5-Phases

We take pride in working with clients to help solve their pressing issues and turn challenges into opportunities.      To deal with the extra-ordinary complexity posed by the sunset of LIBOR and the replacement with SOFR or Ameribor (in the USA), we created a specialist division at our firm that focuses only on issues resulting from LIBOR Transition and Conversion.  Our LIBOR division brings not only unparalleled industry expertise and experience but also artifacts and solutions to execute our 5x5 framework for LIBOR Transition and Conversion:  Our Services and Solutions executed in 5 phases to resolve impacts to the 5 dimensions of organizations.

Our singular goal is to ensure a complete transformation of the client organization and enable it to thrive in the post-LIBOR world.  Our LIBOR division helps mid-size and small financial institutions to: Fully understand and assess transition risks and impacts across the entire organization; Develop strategic roadmaps with prioritized initiatives and milestones; Cohesively execute transition initiatives by automating intelligently and conversion initiatives by using AI technology. 

Our Services and Solutions for LIBOR Transition and Conversion

     Education and Assessment

  • Providing Senior Management education

  • Assessing and documenting key issues, exposures, impacts

  • Identifying and Evaluating impacts of transition and conversion for your business, financials, operations, technology, and legal+enterprise functions

  • Analysis and recommendations for remediation and validation

     Strategy     |    Roadmap   |  Initiatives Prioritization

  • Create LIBOR Transition and Conversion Roadmap 

  • Create Execution Program of changes and sequencing for business, operations, financials, technology, and organization functions of legal/tax/accounting/reporting

  • Create Transition Program, Conversion Program, establishing communication, management, monitoring and governance

     Execute Roadmap, Programs, Initiatives, Technology

  • Bring Artifacts, Templates, Samples, Resources 

  • Program and project leadership and/or management

  • Program execution for Business, Finance, Operations, Technology, Communication, and other Enterprise functions 

     Transformation, Testing, Training, Support

  • Enable organizational transformation for post-LIBOR world 

  • Operate in parallel with new rate indexes until needed

  • Product, Process, Technology Testing

  • Support, Training, and Post-implementation Enhancements

   Conversion of legacy agreements, contracts, products at machine speed using AI

  • Strategy for when and how to convert documents, products, systems

  • Communication strategy with Customers, Counterparties, and Vendors

  • Accelerate legacy contract remediation by using technology to:

    • segment legacy LIBOR documents by terms/product/customer for complexity and risk

    • “read, index, remediate” legacy LIBOR disclosures/contracts/products at machine pace and scale, directly in systems of record

Initiatives for 5 Dimensions of Organization Impacted by Transition and Conversion 

   Business:  Products/Customers | Treasury | ALM & Risk

  • Business risk and return impacts from transition & conversion of products, derivatives, agreements, models, frameworks

  • Communication strategy for customers, counterparties, vendors, regulators about new products and conversions

  • New product design, pricing, timeline, hedging, policies

  • Liquidity, Cash, Income/Expense forecasting and monitoring

  • Cost of funds recalibration; hedge ratios of new derivatives

  • Portfolio and ALM risk-limits for scenario analysis with SOFR

   Financial:   Modeling |   Valuation  |  Accounting

  • Evaluate changes to Forecasting, and impacts to Cashflows, Earnings, Expenses

  • Quantify financial exposure and impacts to Balance Sheet

  • Evaluate and Acquire SOFR models; Validate Models  

  • Estimate impacts to Risk; VaR, DFAST, PPNR, CECL, CCAR

  • Evaluate effects of Re-striking; Valuation changes for “spread”

  • Verify Hedge Accounting

  • SOX considerations for valuation certification

Operations:  Data/Calculations | Workflows | Processes

  • Redesign processes for:

    • Data capture, verification, calculation, usage methods

    • Trade Acquisition, Settlement, Confirmation, Systems

    • Servicing and Payments/Receipts 

    • Collateral valuation processes

  • Provisions to accommodate vendor upgrades of software

  • Redesign processes for new products, models, 

   Technology:  Automation & Digital Transformation

  • Map vendor dependencies to integrate with legacy systems

  • Update systems to capture and process both Legacy and new data, sources, calculations, methodologies, models, products, reporting

  • System code changes to make payments adjustment

   Legal + Enterprise Functions of Tax, Risk, Governance, Others

  • Digitize all legal documents

  • Use AI technologies to evaluate the “absence, existence, and strength” of Fallbacks

  • Create Taxonomy of documents and Prioritize based on Fallbacks and customer cohorts

  • Evaluate Tax considerations of instrument and derivatives valuation changes, and value transfer monetization

  • Evaluate Tax consideration of unwinding or re-striking

  • Evaluate Regulatory and Reputation Risks

  • Update Policies, Procedures, Controls

  • Update Disclosures and Reporting