Bank of Ireland Benchmark Reform Hub


 
Benchmark rates, also known as interest rate benchmarks and reference rates, are used in various different types of financial products and contracts and reflect what it costs for banks to borrow from each other. Traditionally, benchmark rates have been determined by using the expert judgment of a contributing panel of banks and are calculated and published daily by an independent industry body. Benchmark rates are used selectively by banks in some, but not all, products and services. Bank of Ireland UK, like other banks, have used benchmarks such as the London Interbank Offered Rate (“LIBOR”) and Euro Interbank Offered Rate (“EURIBOR”) in business or corporate transactions as well as bank to bank transactions.

Since 2014, financial institutions worldwide have been progressively moving towards replacing or reforming benchmark rates in what is known as Benchmark Reform.

Benchmark Reform involves the introduction of new alternative reference rates to replace certain existing benchmark rates as well as the reform of other existing benchmark rates to become compliant with the Benchmark Regulations. The new benchmark rates are designed to be Risk Free Rates (“RFRs”) and are largely based on actual transactions with minimal reliance on expert judgment from contributing banks. As a result they will be more transparent and reliable.

In Europe, EURIBOR’s methodology was reformed in 2019 (“Reformed Rates”) to comply with EU Benchmarks Regulation.

As a result of the changes, new and reformed benchmarks will be more transparent and reliable.

Bank of Ireland UK’s Transition Preparations

Financial institutions including Bank of Ireland UK continue to plan for the transition to new benchmarks. The new or reformed benchmarks most applicable to Bank of Ireland UK are Sterling Overnight Indexed Average (“SONIA”), Secured Overnight Financing Rate (“SOFR”) EURIBOR and Euro Short Term Rate (“€STR”).

Sterling LIBOR
Please see here for link to the announcement on 5th March 2021 in which the Financial Conduct Authority (“FCA”) announced that all tenors of Sterling LIBOR will either cease to be provided or no longer be representative after 31st December 2021 and therefore can no longer be relied upon for use in loan and derivative markets. https://www.bankofengland.co.uk/news/2021/march/announcements-on-the-end-of-libor

In advance of the pre cessation announcement, the FCA, Bank of England (“BoE”) and the Working Group on Sterling Risk-Free Reference Rates (“RFRWG”) released updated milestones for the transition of LIBOR in advance of the end of 2021 year end deadline along with a useful guide on recommended replacement rates for commonly used products. SONIA is expected to replace Sterling LIBOR in global wholesale financial markets by the end of 2021.To meet these milestones Bank of Ireland UK has taken the following steps:

  • As of 1st October 2020, Sterling LIBOR linked products that mature beyond 2021 no longer form part of the Bank’s standard product offering, and alternative rates are available to customers. The rates available will differ depending on customer requirements and product type. These rates may be drawn from the Bank’s existing product suite or be based on SONIA. Your relationship manager will be in touch in the coming months to discuss the options available to you on transition.
  • From 1st April 2021, new Sterling LIBOR linked products and loans will no longer be offered by Bank of Ireland UK.
  • You will note from the BOE guidance that SONIA is likely to be used by the large corporate market and SMEs are likely to move to pricing using the Bank of England Base Rate. In line with this approach, Bank of Ireland UK transitioned new business lending, including Commercial Finance, away from LIBOR on 1st July 2020.

 

As all tenors of GBP will no longer be representative after 31st December 2021, if you have Sterling LIBOR linked contracts that extend beyond end 2021, Bank of Ireland UK will engage with you in the coming months to amend your products and contractual arrangements to facilitate transition away from LIBOR.  Using the Bank of England guidance, replacement rates offered will be drawn from the Bank’s existing product suite or will be based on risk-free rates.

US Dollar LIBOR
The FCA has announced on 5th March 2021 that the LIBOR settings for US dollar will either cease to be provided or no longer be representative after:

  • 31st December 2021 for the 1 week and 2 month US Dollar settings.
  • 30th June 2023 for the remaining US dollar settings.

In the US, the Alternative Reference Rates Committee (ARRC) selected SOFR as its recommended alternative to US Dollar LIBOR. The US regulator, the Fed, has set out recommended transition guidance, which states that new issuance of US Dollar LIBOR instruments should stop as soon as practicable and in no case later than end-2021. To deliver against this guidance, Bank of Ireland UK  intends to cease issuing USD LIBOR for new contracts by end of 2021. This is in line with current regulatory guidance but may change.

The cessation date for the 1 week and 2 month tenors of US Dollar LIBOR is 31st December 2021. If you have US Dollar LIBOR linked contracts referencing these tenors that extend beyond 2021, we will engage with you in the coming months to arrange a transition to an alternative rate. Replacement rates offered will be drawn from the Bank’s existing product suite or will be based on risk-free rates to suit customer and product requirements.  If you have any queries please talk to your Bank of Ireland UK Relationship Manager or get in touch at Benchmarkinfo@boi.com.
The FCA announcement means that certain tenors of US Dollar LIBOR (overnight, 1 month, 3 month, 6 month and 12 month) will continue to be published until 30th June 2023. As a result, if you have US Dollar LIBOR linked contracts using these tenors that extend beyond this date, they will remain unaffected for the moment and Bank of Ireland UK will engage with you in advance of June 2023 to amend your products and contractual arrangements to facilitate a transition away from LIBOR.

The following are some questions and answers that will help you understand Benchmark Reform and how it might impact any products you hold or transact in with Bank of Ireland UK. We have also included some links to external websites where you can find out more about Benchmark Reform.

What are Benchmark Rates?

Benchmark rates are regularly updated interest rates that are publicly accessible.
Benchmark rates have been fundamental to interest rate markets for decades and banks can choose to use these in the pricing of their products and services. In Bank of Ireland UK, benchmarks are generally used in business and corporate loans and financial product. The most commonly used benchmark is LIBOR, which is now being replaced by alternative benchmarks such as RFR’s or central bank rates such as the Bank of England Base Rate.

 

What is Benchmark Reform?

The financial crises in late 2008/2009 highlighted liquidity and reliability issues with LIBOR benchmarks and caused regulatory bodies to scrutinise how benchmarks are set and administered.

Since 2014, financial institutions worldwide have been progressively moving towards establishing new Risk Free Interest Rate benchmarks to replace or reform benchmarks. In 2019, EURIBOR reformed its methodology to be compliant with regulatory requirements and can continue to be used. However, the FCA in the UK have stated that the majority of  LIBOR rates will not be published after the end of 2021.

Replacement benchmarks or Risk Free Rates (RFRs) differ from traditional benchmark rates in that they are designed to be based on actual transactions, with minimal reliance on expert judgment from contributing banks. These new rates will replace traditional benchmarks such as LIBOR for interest rate-linked products, and financial instruments, such as fixed income securities, loans and derivatives. This move to Risk Free Benchmark Rates is commonly known as Benchmark Reform.

 

Why are you telling me about it now?

We want to let customers know that reform is underway and how it may impact on your financial requirements and products.

In early 2020, Industry and Regulatory Authorities set dates after which LIBOR rates can no longer be offered for new products. Replacement products for Sterling LIBOR have been available to customers since 1st October 2020, and for periods after 31st March 2021, Sterling LIBOR can no longer be used for new products.

In order to support this industry and regulatory position, Bank of Ireland UK transitioned new business lending, including Commercial Finance, away from LIBOR to the BOIUK Base Rate, which uses the Bank of England base rate as a benchmark, on 1st July 2020.

As of 1st October 2020, Sterling and US Dollar loans based on LIBOR are no longer freely available and have been replaced by alternative products drawn from the Bank’s existing product suite or based on risk-free rates. Other than Sterling and US Dollar LIBOR loans, our full range of loan products and services will continue to be available.

Bank of Ireland UK does not intend to offer new products based on US Dollar LIBOR after 31st December 2021, in line with current regulatory guidelines which state that issuance of new LIBOR instruments should stop as soon as practicable. This milestone may change depending on market developments.

Although benchmark reform is not applicable to all of our products or to every customer, where it is applicable, we are planning for a smooth transition to alternative rates in advance of the applicable cessation deadlines.

For customers with existing LIBOR loans maturing in 2022 and beyond, we plan to be in touch with you during 2021 to discuss the transition options available to you.

 

Could this impact me?

Benchmark rates are most common in banking products used by business or large corporate customers. As an example, for some business loans the overall interest rate applicable to the loan would be determined by using a benchmark rate plus the Bank’s lending margin. Commonly used impacted benchmarks in Bank of Ireland UK are Sterling LIBOR and US Dollar LIBOR rates.

EURIBOR has updated its methodology to be compliant with regulatory requirements and will be available beyond 2021.

If you are a customer who has traditionally used LIBOR pricing, you need to be aware that Bank of Ireland UK transitioned new business lending, including Commercial Finance, away from LIBOR to the BOIUK Base Rate, which uses the Bank of England base rate as a benchmark, on 1st July 2020.

As of 1st October 2020, new LIBOR loans are no longer freely available. Replacement rates available to customers include fixed rates, the BOIUK Base Rate and risk-free rates. The Bank of England published a useful guide to recommend replacement rates.

Customers using sterling LIBOR linked products or US Dollar LIBOR linked products using the 1 week or 2 month tenors maturing in 2022 and beyond will need to transition to replacement rates prior to the end of 2021. Customers using US Dollar LIBOR linked products applying the other tenors (overnight, 1 month, 3 month, 6month, 12 month), maturing beyond 30th June 2023 will need to transition to replacement rates before this date.

We will be in touch with all impacted customers to discuss the options available to you. In addition to loans, customers who use interest rate swaps or derivatives for risk management purposes will be impacted by this reform. Your relationship manager will support you in the transition to replacement rates.

As always, if you would like to discuss this, please do not hesitate to contact your relationship manager or email us on benchmarkinfo@boi.com.

 

Why can we not just move customers to these new Risk Free Rates now?

Market developments are still progressing in relation to certain elements of Benchmark Reform. For example, RFRs are not suitable for all customer or product types, as outlined in the guidance published by the Bank of England, and banks such as Bank of Ireland UK need to ensure that the alternative rates which we move customers to are right for both the customer and the type of product held.  Bank of Ireland UK is currently keeping track of industry developments.

During 2021 we will be in contact customers who have existing LIBOR products about the replacement rate options and transition mechanisms available to them.

If you have any queries, please get in touch at benchmarkinfo@boi.com.

What happens next?

No new sterling LIBOR products will be issued from 1st April 2021 and alternative rates to LIBOR are now available to customers. Products are drawn from the Bank’s current product suite, or based on new risk-free rates.

If you have an existing LIBOR product as outlined below, a future switch to an alternative rate by the applicable cessation date is required:

  • Sterling LIBOR linked product maturing after 2021 or
  • US Dollar LIBOR linked product using the 1 week or 2 month tenors maturing after 2021, or:
  • US Dollar LIBOR linked products using the overnight 1 month, 3 month, 6 month and 12month tenors, maturing beyond 30th June 2023

Be assured that we will contact you to ensure that contract terms and conditions are adequate to allow for potential changes or impacts resulting from Benchmark Reform. If required, contracts will be updated to facilitate a move to a replacement rate to ensure continuity of the contract past the applicable cessation date. There is no need for you to do anything just yet.

Bank of Ireland UK will guide you through the Benchmark Reform and transition impacts as they relate to your products and specific requirements. We will also bring your attention to revised terms and conditions to protect you and your product from possible changes due to Benchmark Reform.

If you would like to know more please get in touch with your relationship manager or send us an email on benchmarkinfo@boi.com.

 

If you would like more information

If you would like some more information we have some web links for your reference below, or please feel free to get in touch with us at Benchmarkinfo@boi.com.

  1. UK
    https://www.bankofengland.co.uk/markets/transition-to-sterling-risk-free-rates-from-libor
  2. Europe
    https://www.ecb.europa.eu/paym/initiatives/interest_rate_benchmarks/WG_euro_risk-free_rates/html/index.en.html
  3. US
    https://www.newyorkfed.org/arrc
  4. Use Cases of Benchmark Rates – Recommended Replacement Rate Guide
    https://www.bankofengland.co.uk/-/media/boe/files/markets/benchmarks/rfr/use-cases-of-benchmark-rates-compounded-in-arrears-term-rate-and-further-alternatives