LIBOR Transition: ISDA Protocol – Customer Swap Programs

Banks with a customer swap program have to be thoughtful around LIBOR transition for customer swaps as it is unlikely that the end-user bank customer will adhere to the ISDA Protocol due to its complex nature (albeit some Banks may be directing their end users to try to do so, and we continue to recommend our Banks do adhere – see link). Additionally, a review and potentially an amendment to the promissory note related to a customer swap maturing after June 2023 is recommended in order to support a proper transition away from LIBOR. Therefore, banks with customer swap programs will want to consider a few steps to incorporate LIBOR fallback language into their loans and swaps properly. Banks should consider the following guidelines when preparing their end-user bank customer transactions for LIBOR transition.

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