Today, the Association for Financial Markets in Europe (AFME), together with international law firm, Simmons & Simmons, has published the second in a series of papers, entitled ‘LIBOR Transition: Managing the Conduct and Compliance Risks – Client Communications’.
The latest paper in the series provides practical guidance to Senior Managers and Legal and Compliance teams on managing conduct risks related to client communications posed to firms engaged in the transition away from the London Interbank Offered Rate (LIBOR) to alternative rates. The paper focuses on considerations for client communications – from establishing an effective strategy through to monitoring and record-keeping.
The first paper, published in December 2019, identified ways in which firms can seek to mitigate the key conduct risks posed by LIBOR transition when establishing their governance structure.
Rather than offering a prescriptive checklist that may only apply to a handful of firms, the paper takes a broader view, basing the guidance on the fundamental understanding that different firms will be impacted by the LIBOR transition in different ways.
Richard Middleton, Managing Director, Head of Policy at AFME, said: “Client communications and awareness are key to delivery of firms’ LIBOR transition plans. Firms will need to focus on the broad range of client needs and the end-to-end user experience, as well as considering how the current COVID situation may have impacted their transition timeline.”
LIBOR Leads Penny Miller and Caroline Hunter-Yeats at Simmons & Simmons, commented: “Client engagement on the LIBOR transition will differ for every firm and this paper provides practical guidance for firms on their approach to client communications and, with the help of the AFME committee members, we have provided questions that firms should consider when planning their client communications .”
Download the paper here
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