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OCC and Risk I: LIBOR Cessation

The regulators are coming. In summer 2019, the SEC flagged the risks around LIBOR cessation and provided guidance around managing risk for the entities it…

OCC Risk Assessment II: Leveraged Lending

As discussed nearby, while the OCC’s Semiannual Risk Assessment flagged LIBOR cessation as an emergent risk, its tone was balanced on credit risk. First, the…

Simple Minds?

There has been considerable discussion about the variants of SOFR on these pages (and at the LSTA Conference last week in the Introduction to LIBOR…

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