Do recent developments mean "pens down" on LIBOR transition plans? And how do those developments affect ISDA’s work on benchmark reform? In this 13th episode of the Dechert LIBORcast, Matt Hays and Karen Stretch pose these questions and more to ISDA CEO Scott O’Malia.
Do recent developments mean "pens down" on LIBOR transition plans? And how do those developments affect ISDA’s work on benchmark reform? In this 13th episode of the Dechert LIBORcast, Matt Hays and Karen Stretch pose these questions and more to ISDA CEO Scott O’Malia.
Welcome to Dechert's LIBORcast, where industry leaders come to talk LIBOR transition.
Matt Hays:Hello everyone, and welcome to this, the lucky 13th installment of the Dechert LIBORcast. I'm Matt Hays, a partner in the global finance practice at Dechert based in Dechert's Chicago office. I lead our asset-backed securitization team, as well as our LIBOR task force. My co-host in today's session is Karen Stretch, a partner based in our London office, who is part of our financial services team and whose practice focuses on derivatives and related matters. Karen, welcome to the show.
Karen Stretch:Thanks, Matt. We are delighted to be joined today by Scott O'Malia, chief executive officer at ISDA. On Monday, January 25, the ISDA 2020 IBOR fallbacks protocol and supplement went live. As of the go live, ISDA reported that more than 12,000 entities across nearly 80 jurisdictions had adhered to the protocol. There is a lot of information resources available on LIBOR transition and benchmark reform. Before we start the questions, Scott, it would be great for our audience if you could give us a recap on your role, and ISDA's work on benchmark reform and transition from LIBOR so far, including a little bit more on the fallbacks protocol and supplement that went live late last month.
Scott O'Malia:Well, thank you very much, Karen and Matt, for having me thank you to Dechert for hosting. As you mentioned, I am the chief executive of ISDA, and ISDA is the global trade association with more than 950 members worldwide serving all aspects of the derivatives market. Prior to this role, I was also a commissioner at the CFTC from late 2009 to 2014. We implemented the Dodd-Frank rules and of course conducted the investigation into LIBOR. Now, since then, in this role, we've been working very closely in the benchmark reform and it's been actually several years since first asked by the Financial Stability Board's official sector steering group back in 2016, they requested ISDA get involved in this. And we were asked to develop a workable and consistent fallback methodology for derivative contracts, referencing LIBOR and other key IBORs. Now, as you know, the fallbacks previously written into derivative contracts simply would not have worked had an IBOR become permanently unavailable, a situation that was looking increasingly likely even back in 2016. The calculation agent would have been required to call up dealers and ask them to give an estimate of what the IBOR would have been. Dealers are extremely unlikely to do this if an IBOR becomes permanently unavailable, and they certainly wouldn't want to do this every day for potentially years. So firms would have ended up with a chaotic and uncertain situation without a proper fallback in place. Now, the new fallbacks, which we've worked on through this period from 2016 on, are designed to avoid that situation, essentially provide a one-size-fits-all safety net in the event the IBOR disappears while firms have exposure to that rate. They're based on robust risk-free rates that have been identified by the various jurisdictions in their working groups. So firms can have the certainty that the viable alternative will automatically kick in if an IBOR ceases to exist or, in the case of LIBOR, the UK FCA determines that a rate is no longer representative of the underlying market. Now, we published the IBOR fallback supplement and the IBOR fallbacks protocol back in October, and the supplement incorporates the fallbacks into new covered IBOR derivatives referencing the 2006 ISDA definition entered into from January 25th of this year, unless a party agrees not to use that the IBOR fallback protocol includes fallbacks into legacy non-clear derivative trades that other counterparties that choose to adhere to the protocol. So it's really an efficient way to amend multiple legacy contracts with multiple counterparties, all in one go, I should also note that the clearing houses have also adopted the same fallbacks into their rule books. So those contracts will be effectively managed. Now, as you mentioned, when the fallbacks took effect on January 25th, more than 12,000 entities from nearly 80 jurisdictions had adhered to the protocol, which will go a long way to mitigate the market disruption if a key IBOR ceases to exist or is deemed non-representative. Now according to analysis by the UK FCA, over 85% of non-clear interest rate derivatives in the UK referenced Sterling LIBOR, and now have an effective fallback in place because both parties have agreed to adhere to the protocol. So it's a big job done. It's a big relief that we got so much uptake, and we really believe this is a successful implementation of the fallback work.
Karen Stretch:Thanks, Scott. The market was taken somewhat by surprise at the end of last year with the ICE Benchmark Administration announcements and then consultation, the IBA consultation closed for comment on the same day the ISDA changes took effect. Whilst we wait for the formal outcome of the consultation, it seems certain that instead of the end of 2021, IBA will continue to provide the most popular dollar LIBOR tenors, or settings to use the more technical term, until the end of June 2023. To those not as close to these issues as you or I, it could be easy to think that this is extra time and there's no immediate need to worry about LIBOR transition. What is ISDA's view on the potential extension and does this potential delay or extension mean market participants don't need to worry about LIBOR transition?
Scott O'Malia:Well, they definitely need to worry about LIBOR transition. Regardless of whether this was a surprise or not, firms certainly shouldn't assume that this means that they can dial back on any benchmark reform efforts. For one thing, most LIBOR settings, including all Euro, Sterling, Yen and Swiss Frank settings, are expected to cease at the end of this year, 2021. Second, U.S. regulators have made it clear that they also expect firms to stop using LIBOR, U.S. dollar LIBOR specifically, for all new trades after 2021 subject to maybe a few exceptions. Also in a recent speech, the FCA's Edwin Schooling Latter, who's been very involved in this reform effort, suggested that the UK regulator could also heavily restrict the use of new U.S. dollar LIBOR after the end of 2021. So derivatives users still need to prepare to use alternative reference rates, at least for new transactions, by the end of this year. Now the proposed mid-2023 end date for most U.S. dollar LIBOR settings means that a large chunk of existing positions will naturally roll off, but firms will still need to deal with the remainder of their legacy U S dollar LIBOR portfolio, which could include longer-dated tough legacy exposures in certain Castro instruments, and in some cases, derivatives that hedge those exposures. Now, of course, this could take some time and that's why they've, I think, given some accommodation on the timetable to help manage that now, plus many regulators are also encouraging firms in their jurisdictions to ensure that the use of robust fallback language is included in all contracts as soon as possible. And we know that obviously the strong uptake of the fallbacks was quite useful in managing that situation.
Karen Stretch:And moving to focus on ISDA's work itself, ISDA is clearly continuing its transition efforts. What can you say to us today about the impact of the IBA consultation on ISDA'S work?
Scott O'Malia:Well, it really doesn't have much impact on ISDA's work per se. It certainly doesn't remove or lessen the need for robust workable fallbacks, or the importance of agreeing to them in a timely manner. The result of the consultation, however, could inform how and when fallbacks would apply.
Karen Stretch:So what do the announcements mean for ISDA's work?
Scott O'Malia:Well, any announcement of an IBOR cessation would trigger a fixing of the spread adjustment under the fallback methodology, to quickly give some context. The fallbacks are based on the RFRs identified by the relevant public sector, working groups in each currency. However, these RFRs are adjusted to reflect structural differences between the IBORs and the RFRs. IBORs are available in multiple tenors and incorporate a credit risk premium as well as other factors, while the RFRs are overnight rates. Now, the adjustment is intended to reduce the chance of contracts originally based on IBORs, diverging far from the counterparties' original expectations after the fallbacks take effect. Now following multiple industry consultations, it was determined that the fallback for each IBOR setting would be based on the relevant RFR compounded in arrears to address the differences in the tenor, plus a spread calculation, using a historical median approach over a five-year lookback period to account for the credit risk premium and other factors. Now, according to Bloomberg's IBOR fallback rate adjustment rule book, which we are using to disseminate this, the spread adjustment for a particular fallback will be fixed at the point that relevant IBOR benchmark administrator, the administrator's regulator, or a defined authority announces that the IBOR setting will cease to exist, or is, in the case of the FCA, deemed to be non-representative. Now, an announcement by IBA or the FCA that the various IBOR settings will end or become non-representative on certain dates would therefore trigger the fixing of the spread for all settings. At that point, even if the actual cessation or the non-representative dates are different. So what that means for U.S. dollar LIBOR in particular, well, there are some nuances. If it is confirmed that one week- and two month- U.S. dollar LIBOR will end on December 31st of 2021 with the remaining U.S. dollar setting ceasing at end of June 2023, then all U.S. dollar LIBOR settings will continue to be published until the end of 2021. After that point, one week- and two month-U.S dollar LIBOR would cease, but the new fallbacks would not actually take effect. Instead, the calculation agent would compute the replacement rates for those tenors using linear interpolation. For example, calculating the one-week rate by interrelating between overnight and one month on U.S. dollar LIBOR, the fallbacks for all U.S. dollar LIBOR settings would take effect at the end of June 2023, assuming that the remaining U.S. dollar LIBOR tenors cease to be published as proposed or become non-representative. A bit complicated, but it's all laid out in the rule book.
Matt Hays:So what should market participants be most concerned about on the LIBOR transition going forward?
Scott O'Malia:I would say it's time. This can't be left until the last minute. Benchmark reform is a massive undertaking that touches on all asset classes, all jurisdictions and all aspects of a firm's business. Don't underestimate how long it will take, even though the most popular U.S. dollar LIBOR settings may be published until mid 2023, firms still need to be ready to shift to the alternative rates for new trades at the end of this year.
Matt Hays:We talked about fallbacks. They clearly play an important role, but has ISDA developed a methodology for the spread adjustment that Bloomberg's already publishing on an indicative basis? How is that spread adjustment methodology determined?
Scott O'Malia:Great question. The spread adjustment is based on a clear, transparent methodology and was developed following multiple consultations to achieve a consensus across both the buy-side and sell-side, as well as the official sector. As you noted, indicative spread adjustments and all in fallback rates are published by Bloomberg. So anybody can see what the spread adjustments would be at any time. It's completely transparent. In addition, other markets are adopting a similar methodology for their fallbacks as well. For example, the ARRC has recommended a spread adjustment methodology for cash instruments that aligns with ISDA's fallback. The FCA has also stated that it will use the same spread adjustment to calculate any synthetic LIBOR that is also subsequently published.
Matt Hays:Does the extension in LIBOR create any concerns for you about the spread adjustment methodology?
Scott O'Malia:No, not really. I mentioned previously the spread adjustment will be calculated at the time any cessation or non-representative announcement is made. The fact that different U.S. dollar LIBOR tenors may have different end dates would not impact when the spread is fixed, if the announcements were made on the same day.
Matt Hays:So another hot topic question we get is, do you think there is any risk that either the market shifts or the methodology changes given the extension?
Scott O'Malia:No, I don't think so. We developed this after extensive consultation over four years and was intended to work on a number of different scenarios. It is also now hard-wired into the Bloomberg rule book for publication of the new indicative and future actual fallback rates. Fixing the spread at the point of cessation or non-representativeness, provide certainty and clarity to the market over what the fallback rates would be. I would argue that obviously over 13,000 participants have adhered to this, which means there's massive uptake and people really understand now what's in it. What's in the fallback rate, how it'll be used and, and when it will be implemented. So I think over literally years, the education and information we've provided will lead to a successful adoption.
Matt Hays:Great. In the new year, we've already seen a lot of focus on the importance of transitioning now and encouragement that the market start using new risk-free rates. Do you think they will start using risk-free rates and should they start using them now?
Scott O'Malia:Absolutely. Now, most laborious settings are expected to cease after the end of 2021. So maintaining the status quo really isn't an option, even if the U.S. dollar LIBOR settings are published until mid 2023, regulators have made it clear that LIBOR should not be used for new trades after the end of 2021. Liquidity and alternative rates, such as the RFR has been growing, particularly in established rates like SONIA. According to ISDA's analysis we publish with Claris, 45.9% of total cleared Sterling interest rate derivatives was linked to SONIA in January of this year. However, there is still some way to go on some other products, the percentage of clear trading activity and SOFR was only 5.6% of total U.S. dollar interest rate derivatives, the DVO one measurement transacted during that month. So there's still some work to be done on SOFR. Ultimately, though, the only way for liquidity to increase is for people to take the leap and begin trading the product.
Matt Hays:So on SOFR, do you think rates other than SOFR will be used in the U.S.?
Scott O'Malia:We're agnostic on that question. And as to the alternative rates that are ultimately used, this is a decision that counterparties need to make. While RFR is, are arguably the most suitable for the majority of derivatives trading, other rates may be suitable as well as such as for hedging purposes. Indeed several alternatives have emerged already. We think firms should adopt whatever rate is best for them, and ISDA will soon publish rate options to allow counterparties to trade merit board derivatives if they choose to do so. For example, a hedge to an Ameribor loan would be available. Such documentation solutions will follow as the markets develop.
Matt Hays:What do you think will motivate market participants to start using the new rates and move away from LIBOR?
Scott O'Malia:That's a great question. And a question we ask, you know, market participants frequently, but I do think that we will start to see more liquidity in alternative rates rise steadily as we approach the deadline in 2021. There's unlikely to be a single catalyst that triggers significantly more trading activity. But having said that, the increase in the issuance of loans and cash bonds reference to these alternative rates, both public and private sector will undoubtedly trigger more trading of derivative products, referencing those rights. It's a bit like your homework. Sometimes people just leave it till the end.
Matt Hays:So when do you think it's likely that we'll have a term SOFR rate?
Scott O'Malia:I think that's a really good question for the ARRC, the Alternative Reference Rate Committee. They originally penciled in the development of a forward-looking SOFR term rate by the end of the first half of 2021 in its pace transition plan. Last September it published a request for proposal, for an administrator to publish such rates. However, the development of the forward-looking SOFR term rate ultimately depends on there being sufficient liquidity and SOFR derivative markets so the administrator can produce such a rate. In connection with the ARRC's request for proposal, we understand that several administrators are considering offering a forward-looking SOFR term rate. So I think the best answer and the simple answer is we have to wait to see
Matt Hays:Related issues in this area, tough legacy for on jurisdictional issues. What's your current view on tough legacy and how those possible statutory solutions interact with the fallback work you're doing?
Scott O'Malia:I really don't have any insight on the progress of any legislative solutions, but they would seem to offer a way to resolve the tough legacy issue in those predominantly cash contracts, where there's not possible to make a contractual amendment. So the UK, U.S. and EU have all suggested possible legislative solutions. For instance, the FCA has proposed using a synthetic LIBOR that would be used in certain limited circumstances. The most important thing is that these solutions work together and avoid completely different and colliding approaches. We understand regulators are coordinating closely on this, which is certainly a welcome step. Prospective legislative solutions haven't had any impact on our contractual fallback work. Regulators have stressed that firms should continue to amend contracts, to incorporate replacement rates and implement the contractual fallback.
Matt Hays:So on industry engagement, does ISDA get a sense both from your members and maybe market participants more broadly that they're engaged in the LIBOR transition?
Scott O'Malia:Yeah, absolutely. This has been a priority for our board and our membership for some time now. In fact, the last couple of years interest in the subject is dominated, and has been demonstrated by the number of people who attend our benchmark events and visit our website, which have increased markedly over the past 12, 18 months. We had great participation on our consultations as well. I think the overwhelming majority of firms now know that most LIBOR settings will cease at the end of 2021 and have transition projects in place. Now, this wasn't the case a couple of years ago, but education and outreach by regulators and the various trade associations like ISDA have helped get the message across. And this is something that everyone needs to engage in. I think in adhering to the protocol as well, that had to go through from governments, whether you're an asset manager or a sell-side or a pension fund. And I think that helped really crystallize what was at stake. And the fact that we did have over 13,000 participants really demonstrated that people were thinking this through and working towards that common end. And the proof is in the pudding. Strong adherence is an indicator that people work through this problem internally to get to the solution.
Speaker 1:For those that may not be engaged right now, do you have any views on what could be done to increase that engagement?
Scott O'Malia:I think the level of engagement is actually high. That's not to say that all firms are all at the same level of preparedness. Some have more to do than others, and there really isn't much time to get it all done. We are quickly approaching the end of the year. And even though we're talking about this in February, but, you know, in terms of governance and preparing for that, that's not a lot of time. As we've seen over the past several years, the public private sector, working groups like the ARRC and the working group on Sterling risk-free reference rates, which I'm a member of, have set out very helpful timelines for transition in the UK. For example, the end of the first quarter of 2021 has been set out as the date to stop using a new LIBOR lending. The ARRC has set out a similar best practice timeline for the U.S. dollar LIBOR business loans. And with the end of the second quarter of 2021 as their target, it's important market participants understand those timelines and are prepared for those changes, both at a kind of a documentation level, but also at a trading level.
Matt Hays:So do you have any concerns that the extension will give the market the greenlight to procrastinate? And, and is there anything you say to those that interpret it that way?
Scott O'Malia:No. The regulators have made clear that the firms should not use U.S. dollar LIBOR for new trades after the end of 2021, except in very limited circumstances. That means firms will need to prepare to use alternative rates for at least new trades. From the end of this year, the proposed mid-2023 end of date for U.S. dollar LIBOR settings will allow much of the legacy portfolio to roll off naturally, which is of course very helpful, but firms will still need to have a transition for those longer data traits in additional Euro, Sterling, Swiss Franc, and Yen LIBOR settings. We'll likely see the end of 2021 along with the one week- and two months- U.S. dollar LIBOR and having engaged with regulators over the past years, I can say with good confidence that they are very serious about these dates. These dates are unlikely to move and hope or prayer will not change that up.
Karen Stretch:Can you speak to us about ISDA's current coordination effort? Who is ISDA coordinating with?
Scott O'Malia:Well, we're coordinating in a number of ways. For one thing, we sit on the various public/private sector, working groups in the U.S., UK, EU and Japan among others. We also coordinate closely on fallbacks with the official sector, including the FSB OSSG, the official sector steering group, which is, I think, 30 participants of jurisdictions worldwide. Finally, we're coordinating with trade associations and other asset classes to make sure that we're all on the same page. And, and of course our membership has over 900 members across 70 countries, which also gives us quite a platform to share our views and communicate transition planning.
Karen Stretch:And what's your view on coordination efforts? Both, I guess, domestically and internationally.
Scott O'Malia:Coordination is obviously very important, but we've really been impressed with the global coordination so far while different jurisdictions have taken slightly different approaches to their preferred replacement rates. For example, some are using secure, some are using unsecured. There has been close cooperation on how to proceed through the organizations like the FSB OSSG, which I think is the ultimate coordinating body. And it also is worth noting that LIBOR in all currencies is regulated by the FCA. The FCA has coordinated very closely with the FSB and with central banks and regulators and other jurisdictions. So whether I am in Australia, Singapore, Hong Kong, Tokyo, the U.S. or Europe or London, which I recognize is in Europe, these are all well coordinated and the regulators are fully aware of what other jurisdictions are doing, and they really are paying attention to what the industry is doing. And so when we talk about our tracking, our indicators, people have a very good sense of the progress being made in the other jurisdictions, both on trading and on, on adherence.
Karen Stretch:What do you think are the risks? If there isn't a coordination effort, are any of them systemic?
Scott O'Malia:Well, a lack of coordination could lead to different approaches being taken by different jurisdictions at a different time. It could massively complicate an already complicated task. It could hamper progress and the ability to shift to alternative rates before a key IBOR ceases and that's not inconsequential, especially with a global market, the way it is having good alignment really helps all countries move, not only countries, but also the markets within those countries move in a coordinated fashion, which is pretty essential.
Karen Stretch:What do you see as the biggest challenge to LIBOR transition compared to the derivatives markets? The cash markets loans and bonds are widely seen as the remaining LIBOR problem areas.
Scott O'Malia:Time. There's still a lot to get done, and only a matter of months until the end of 2021. Some firms really need to accelerate their transition efforts to be there on time. And it's probably in the corporate space. Uh, I'd also like to see more trading and SOFR related products. I think we certainly need to raise that to give people the confidence to go all in, and it's probably the trading in.
Karen Stretch:And so for right now, what are your thoughts on the obstacles to overcome?
Scott O'Malia:Is sufficient liquidity in the alternative rates? There has been an improvement in our far liquidity over the past year, but it's a bit of a chicken or the egg problem firms want to see that liquidity is there before they trade, but they need to enter the market and trade in order to foster that liquidity. Ultimately, I think it will be a steady improvement in liquidity as we approach the end of 2021. I think regulators, particularly in the U.S., are going to make this a, a key focus area and do everything they can to support them.
Karen Stretch:Do you think institutions will be ready?
Scott O'Malia:Mentally? Just like the hallmark analogy you, they will be ready. Most LIBOR settings are unlikely to exist at the end of the year. And as you and your clients would know that doesn't give you a lot of options in terms of, if you don't have the proper documentation ready, if you're not using the current definitions or you're, you don't have an adequate fallback, you're left, you could potentially have a contract frustration event, which would do nobody any good. And so I think the firms will recognize this and take the necessary steps to prepare,
Karen Stretch:Looking ahead to the year ahead of us and beyond, what does ISDA have planned for LIBOR transition this year? What can we expect to see?
Scott O'Malia:Well, we'll continue to support our members in the transition efforts as we head towards the end of 2021. It's participating on outreach, like this podcast which we're grateful to be on, that includes through the publication of documentation solutions as well for hedging. And I swap rates as well as education material on events. We'll also continue to participate in the various public private sector, working groups, and we're needed. We'll consider other documentation in industry solutions.
Karen Stretch:And looking more generally, there remains the ongoing issue of the global Coronavirus pandemic. And following the end of the transition period, we are moving to a new chapter in the UK and the EU. And now we have the recent change of administration in the U.S. so a lot as ever going on. 2020 definitely showed us that everything can change very quickly. And with that in mind and appreciating that this is a big question, can you share any thoughts on how you see the year unfolding?
Scott O'Malia:Well, it's going to be an incredibly busy year for sure. We do have the new administration in the U.S. so market participants will be watching closely how that policy agenda develops. Then the Coronavirus pandemic and climate change have also been highlighted as priorities. So we'll have to see how that translates into specific policy changes. It's good to see my old colleague at the CFTC, Gary Gensler, will be going to the SEC and many other professionals are going to be populating the administration as well. The Brexit transition period ended on December 31st. So firms will be getting to grips with the new environment and what this means for derivatives trading. Lack of equivalence for trading venues has meant that EU and UK participants can only trade on certain liquid derivatives with each other on a staff. We'll keep a close eye on this and see how that evolves into what this means for cross-border trading and market fragmentation. Finally, and importantly, phase five of the initial margin requirements for non-clear derivatives will come into effect on September 1. This will bring more than 3,600 counterparty relationships into scope and that's foreign access. The number of captured in the previous phases, and we'll put an immense strain on the industry's ability to comply, but I don't see that deadline moving. And so firms really need to take the necessary steps in addition to doing everything they can to support IBOR transition.
Karen Stretch:What else can you say to us today about ISDA's 2021 agenda?
Scott O'Malia:Benchmark? Of course, reform will be our big priority as we approach the end of 2021 phase five of the initial margin rules will be the other big focus. We've developed a number of solutions to help firms meet these requirements, including ISDA SIM and the ISDA create, which is an online negotiation platform for multilateral negotiations. We'll be working with our members to ensure that they can access these tools and give them mutualized solutions that can effectively help them repaper and comply with the regulations. As I noted, 3,600 counterparties come into scope. So that's a massive responsibility. This will also be a critical year for the development of local rules to implement the fundamental review of the trading book. These capital rules and revise credit valuation adjustment standards is that we'll continue to support the industry implementation with fact-based advocacy, quantitative analysis and developing mutualized solutions like the ISDA standardized approach benchmarking initiative, which promotes consistent implementation of the standardized approach for calculating capital requirements. ESG will be a focus as well. We'll be focusing on a number of areas, including the promotion of consistent standards and taxonomies and practices for enabling operational efficiency and consistent measurement of ESG progress is the documentation and definitions are already being used to document ISDA derivative transactions. And we seek to make sure that they are adapted to make sure that they're relevant. They're aligned with cash products. They integrate the latest thinking on green taxonomies. On top of all of this, we'll be pushing forward with our various initiatives to promote greater automation and efficiency in derivative markets central to that effort has been the development of the standards to enable digitization of documentation and the automation of post-trade operations. For instance, through the common domain model and ISDA Create as well as the ISDA clause library. The future is a digital platform. The future is making sure that we have digital solutions for all of our contracts, all of our definitions and all of our services. So we're in the process of implementing that. Working with firms like yours, it's very important that we make that transition. It does require some, some changes to kind of practices, to accommodate the digitization effort and people should really look forward to the new digital is the definitions around interest rates, our first natively digital definition.
Karen Stretch:Thanks and Scott, thanks again to you and the ISDA team for taking the time to speak with us today and for providing us this perspective.
Matt Hays:Okay, thank you. We hope you enjoyed listening. Please check out our LIBORcast channel to hear other insightful discussions with market and industry leaders, including regulators, trade associations, and market participants about the work ahead in the LIBOR transition process. Thanks for listening and have a great day.
Speaker 4:[inaudible].