FINRA LIBOR Phase-Out Preparedness Survey

The Financial Industry Regulatory Authority, Inc. (“FINRA”) conducted a survey of common practices implemented by broker-dealer firms to prepare for the transition away from using the London Interbank Offered Rate (“LIBOR”). On August 5, 2020, FINRA published Regulatory Notice 20-26, which lists important considerations when phasing out LIBOR, and summarizes the results of a recent survey of FINRA members to gauge their preparedness for the move away from LIBOR. Importantly, the Regulatory Notice identifies practices that firms have already undertaken to ease the transition. In this Legal Update, we summarize the results of FINRA’s survey by categorizing certain common practices adopted by the surveyed firms.