Transition from LIBOR

LIBOR stands for London Interbank Offered Rate. It’s an index that was originally intended to reflect interest rates that major banks charge each other for short-term loans. LIBOR was used internationally as a benchmark or “reference rate” for setting rates on loans and other financial products.

The effort to replace all LIBORs is an organized global initiative. International working groups were established to identify appropriate ARRs and develop a transition strategy for each currency’s LIBOR. Wells Fargo is an active member of many of the international working groups, including the Alternative Reference Rates Committee in the U.S. We have changed hundreds of thousands of affected contracts and related systems, employing recommendations of the international working groups and trade associations.

LIBOR has been a long-established global benchmark for interest rates, but its credibility has declined over the past decades. During the financial crisis that began in 2007, LIBOR sometimes behaved in unpredictable and volatile ways.

Although improvements have been made to the system, the volume of transactions supporting LIBOR continues to shrink, and the calculation of LIBOR is increasingly perceived as a subjective process based more on hypothetical transactions and judgment than actual transactions. As a result, the regulator of LIBOR called for the market to transition to more robust reference rates.

Regulators worldwide convened currency-based working groups to recommend ARRs to serve as alternatives or replacements for LIBOR, as shown in the following table:

Wells Fargo offers ARRs in addition to those set forth above. For example, in certain products and markets Wells Fargo offers forward-looking term rates published by CME Group (“CME Term SOFR.”). You should discuss the options with your Wells Fargo representative. Wells Fargo may offer other market established benchmarks where there is client demand for them and where appropriate. Customers should independently evaluate and consult their advisors concerning the financial, market, legal, regulatory, credit, tax and accounting risks and consequences of entering into products referencing ARRs.

US and global regulators directed banks to cease offering new LIBOR-based products after December 31, 2021, except in certain, narrowly-prescribed circumstances.

LIBOR is administered by ICE Benchmark Administration Limited (IBA), which is regulated by the Financial Conduct Authority (FCA). LIBOR was historically compiled by IBA on the basis of a panel of banks providing quotes that are intended to be representative of interest rate markets. The FCA and IBA announced that these banks would stop providing quotes after June 30, 2023 for the remaining tenors of U.S. Dollar LIBOR. However, to facilitate an orderly transition for a small number of contracts, the FCA has compelled IBA to continue publishing a “synthetic” version of USD LIBOR in one-month, three-month, and six-month tenors for a limited period. “Synthetic” LIBOR will not be a “representative” rate and will be based on CME Term SOFR plus a fixed spread adjustment.

We have already taken several steps to transition as we continue to listen to customers’ concerns. Here’s what we’ve done so far:

• Provide customer education: It’s important that all of our customers understand this global market change and its impacts. Since September 2018, we have undertaken a major effort to talk directly to customers about the transition and listen to concerns. We’ve already conducted customer outreach in dozens of U.S. cities and our international markets. As the end of LIBOR approaches, we’ll continue to keep our customers informed. 
• Implement new contract language and products: Over the past few years, we’ve encouraged use of more robust “fallback language” in our contracts that contemplates the end of LIBOR. We’ve launched a wide range of products based on ARRs and have developed contract standards and protocols for these products.