This consultation seeks input on whether to add a pre-cessation trigger to the permanent cessation fallbacks that ISDA is implementing for LIBOR in its standard documentation.

The consultation is available here.

Due to the market environment resulting from coronavirus (COVID-19), ISDA is extending the deadline for responses to its outstanding consultation on how to implement pre-cessation fallbacks for derivatives. The extended deadline to the consultation is now Wednesday, April 1, 2020.

Please email your response to FallbackConsult@isda.org and clearly indicate that you are submitting a response in the subject line of your email. For your convenience, you can use this form for your responses (but you are not required to do so). Please note that, subject to the one exception described in the next sentence, affiliated entities will be counted as one market participant for purposes of this consultation and should therefore submit one joint response. As one exception to this rule, asset managers that are affiliated with a bank may submit a separate response that will be treated as separate from the bank group’s response (and the asset manager will be counted as a separate respondent).

In advance of the consultation deadline, ISDA held a webinar on March 4 to go through the consultation. A recording of the webinar is available here. The slide presentation with an annex that includes additional background information is available here.

By participating in this consultation, you agree not to use this process for any anticompetitive purpose, and further agree and warrant that you will not engage in any conduct that would cause any other party participating in this consultation to be in violation of any competition or antitrust law or regulation. ISDA has taken and will continue to take safeguards and protections to ensure that the use of the results of this consultation comply with applicable laws and regulations.