Financial Services Ireland

IBOR reform

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IBOR reform

Will adapting to IBOR reform give you a competitive advantage?

With interbank offered rates (IBORs) set to be phased out as reference benchmarks for interest rates, the financial services industry needs to prepare for the post-IBOR world of 2021 and beyond. But every indication shows that, so far, impacted stakeholders are simply not prepared for the extent of the issues and challenges ahead.

IBOR is coming to an end – is your business ready?

For more than 40 years, the financial services industry has relied on interbank offered rates as a reference rate for variable-rate financial instruments. Now IBOR is coming to an end, driven by:

  • Systemic risk due to the uncertainty surrounding the durability of IBORs
  • Reluctance from LIBOR and EURIBOR panel banks to submit quotes
  • Decline in the liquidity within the interbank unsecured funding markets
  • Charges of attempted manipulation and false reporting

All variants will be replaced by Alternate Reference Rates (ARRs), which includes the heavily relied-upon LIBOR, frequently referenced in derivatives markets. While working groups are still ironing out the details, and there will be variations across jurisdictions, there is no doubt that the transition from IBOR is a certainty and not a choice.

IBOR reform

Huge changes are required for the industry to end its dependency on IBORs by the end of 2021. The transition to ARRs is expected to impact every sector of the financial services industry, including insurance, wealth and asset management, private equity and banking and capital markets. It will have a widespread impact across various functions, business processes and technology.

IBOR transition: key challenges

Given the scale and complexity of this inevitable transition, it is important that market participants initiate steps to prepare now. While 2021 may seem far away, the operational and financial challenges associated with preparing for IBOR transitions are daunting and will take time to work through. Key issues to consider include:

  • Valuation and risk management: value transfer, risk exposures, hedges and modelling
  • Legal – contractual triggers, amendments and client outreach
  • Market liquidity – liquidity in derivatives referencing alternative ‘risk-free rates’
  • Governance and controls – roles, responsibilities and internal control frameworks
  • Accounting and tax – fair value measurement, hedges and tax structures
  • Operations and technology – operational and infrastructure enhancements
What should financial services firms do now to prepare for the IBOR transition?

As the pace of change accelerates firms should take action now, kicking off impact assessments and establishing programme governance. It is also important for institutions to proactively engage with regulatory and industry-led efforts to analyse the complex challenges and develop solutions to mitigate risks to their organisations – and to their clients.

The key to an effective transition will be a robust governance structure that oversees the design and implementation of IBOR transition efforts. With that in mind, the three key actions for firms to take now can be summarised as follows:

  • Ensure clear governance and appoint an IBOR transition team.
  • Perform a comprehensive impact assessment. At a minimum, this should cover: product assessment; legal contract assessment; risk assessment; model assessment, and business process and infrastructure.
  • Create a transition programme and timeline.

The financial services industry has an important role to play in educating end users of financial products on the looming risks of ongoing dependency on IBORs and in guiding them through this transition process. Firms that proactively engage with their customers, and offer new products linked to ARRs, are likely to be at a competitive advantage.

Ultimately, the end of the IBOR era will require considerable planning, cost and effort, and the sooner the financial services industry takes action, the smoother the transition will be.

A version of this article first appeared in the Finance Dublin November 2018 edition.

Thought Leaders


Cormac Kelly

International Banking Advisory Lead

Barry Maher

Director, FS Risk Advisory

Dean Phillips

Associate Partner, Wealth & Asset Management