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Can the Great Libor Migration Happen?

By September 26, 2019December 20th, 2019No Comments

Trillions of US dollars need to start referencing SOFR, the Fed’s new overnight funding rate, very soon. Can the market handle it? Does it want to? Presentations at several NeuGroup meetings in the last few weeks have delved into those questions and the likely demise of Libor. 

In just a few short years – possibly by the end of 2021 – the London Interbank Offered Rate, otherwise known as Libor, may cease to exist. This means that almost $200 trillion linked to the tainted rate, things like derivatives, CDOs, student loans, structured products, adjusted-rate mortgages and the like, will need to be moved to the Fed’s Secured Overnight Financing Rate. 

It won’t be easy. At both recent NeuGroup FX Managers’ Peer Group meetings, members were told that the FCA might declare Libor as an unrepresentative benchmark, which means the FCA will no longer compel banks to submit Libor quotes. Then what? It’s all in the language of change, specifically, fallback language.

  • Fallback language is a key transition element because it facilitates moving existing transactions priced over Libor to a new benchmark. The Fed and its ARRC, along with the International Swaps and Derivatives Association (ISDA), have both proposed such language, the latter in contracts for derivatives referencing Libor and other key interbank offering rates (IBOR). 
  • By the way, ISDA’s proposal drew comments from 147 organizations, and according to association’s results published in December, only seven came from nonfinancial corporates. After that fallback language kicks in. 
  • Good to know. About 95% of Libor contracts are for derivatives

Don’t let it get that far. Although fallback agreements are a good safety net, market players shouldn’t let it get to that point. The easiest solution is for all market participants to transition to the new rate before 2021. But it’s tough sell.

  • Libor: breaking up is hard to do. “Here we are in September of 2019, and I would say that across our client base we really haven’t seen clients pulling away from Libor-based products in advance of the 2020-21 time frame with as much urgency as some have advocated for,” Andrew Little, managing director at Chatham Financial, said in a recent NeuGroup Bank Treasurers’ Peer Group webinar. “As a matter of fact, given the shape of the curve, we’ve seen some clients actually extend the duration of their Libor exposure well out to seven years, 10 years and beyond.

Just what is SOFR? On one hand it’s a mouthful of Fed-speak. In reality, it’s an overnight, risk-free reference rate that correlates closely with other money market rates and is based on actual market transactions. So, it’s a repo rate, and thus backward looking (vs. the forward-looking Libor) and is calculated as a volume-weighted median of transaction-level tri-party repo data collected from the Bank of New York Mellon as well as GCF Repo transaction data and data on bilateral Treasury repo transactions cleared through FICC’s DVP service, which are obtained from DTCC. 

  • The good news is that since SOFR is based on transactions that happened in the tri-party repo market, it’s not easily manipulated. The bad news is that it can be very volatile. During last week’s liquidity crunch, SOFR spiked to a record 5.25%, according to the Federal Reserve Bank of New York, yanked higher by borrowing rates for overnight repurchase agreements, or repos.

Still needs a spread component. Since SOFR is a collateralized or secured overnight rate and Libor is uncollateralized term rate reflective of bank credit, there needs to be some sort of credit spread to adjust for the basis between the two rates.

  • At this point SOFR is too young to create a credit component. When it is more robust then a term rate can be developed, experts say. Regulators also don’t want SOFR to become the new Libor, i.e., a new tool for people to manipulate the market. This means it must be IOSCO compliant and have more of a track record. The International Organization of Securities Commissions published a set of standards for approved global benchmarks back in 2013.
  • Chatham reports that there is a strong interest from the market to develop one soon, although the path forward is still unclear. “I think most of the [Libor-SOFR] conversation reduces in some way to the desire to replicate the time-varying credit spread that is inherent in Libor,” says Todd Cuppia, managing director at Chatham. That reality has increased the relevancy of what he calls the “alternative, alternative reference rates.” The two leading contenders are Ameribor and the ICE Bank Yield Index.
  • Take comfort. For longer-dated Libor contracts, banks and the market may take some comfort from the fact that the historical spread method has already started to be priced into the forward curves. By that measure, “some may say that the transition is becoming priced in to the extent you believe that current basis markets and historical averages are going to be in range of what the different working groups have suggested, which was a multiyear average or median of those rates,” Mr. Cuppia said.
  • “If you look at fed funds as a reasonable proxy for SOFR and you look at the basis between fed funds and Libor, you can see a pretty meaningful decline in those basis rates to what could be a fair representation of their historical average,” he said. “I believe that’s what could be guiding the thinking of those who are using those much longer-term Libor contracts relative to what their alternatives may be.”

No magical thinking, please. Don’t assume that there is a possibility that Libor is staying. Along with the FCA, both the SEC and Fed say that it is going away. Still even the Fed sees resistance (or futility of forcing the issue).

  • “Tellingly, contracts referencing US dollar Libor, without robust fallback language, continue to be written,” the New York Fed’s John Williams said in a speech this summer. He acknowledged the shortcomings of SOFR and replacement benchmarks, but said, “don’t wait for term rates to get your house in order. Engage with this issue now and understand what it means for your operations.”

Perhaps the FCA, Fed and SEC take a lesson from Abraham Lincoln’s observation on a man and his pear tree. “A man watches his pear tree day after day, impatient for the ripening of the fruit. Let him attempt to force the process, and he may spoil both fruit and tree. But let him patiently wait, and the ripe pear at length falls into his lap.”

Jacob Bromsey

Author Jacob Bromsey

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