Amidst COVID-19 concerns, there are ongoing regulatory considerations that require attention. Through our direct involvement in the market and regulatory affairs for all segments of the commercial lending business, AFS has been at the forefront of the coming mandatory transition to SOFR, working closely with the ARRC and other industry leaders to provide clarifications on LIBOR and SOFR.
Are AFSVision and AFS Level III currently capable of supporting the transition? YES! As of April 2021, AFS is the first (and only!) solution provider that can fully support all four SOFR rate methods (including Credit Sensitive Spreads and Compounding Rate and Balance), as well as processing multiple alternative rates (ex., Ameribor, Bloomberg Short-term Bank Yield Index (BSBY), Fed Funds, and Prime Rate). When is LIBOR Going to end? AFS is following guidance from the Alternative Reference Rates Committee (ARRC) that LIBOR will cease as of December 31, 2021. LIBOR might still be available, but not reliable. Why? Because some of the 16- to 20-bank panel will not be providing it to the Bank of England or the FCA. Meaning, the median they will be using to publish will be from a lesser group/number of banks. Therefore, some investors might easily think there could be potential for manipulation and reject the rate. Does AFS offer any custom LIBOR Transition support? Yes, please contact Dean Snyder at DSnyder@afsvision.com or your RM to review your requirements. What Rate is replacing LIBOR? The ARRC selected the Secured Overnight Financing Rate (SOFR) as the recommended benchmark interest rate to be used in place of USD LIBOR. SOFR is an overnight, secured rate based on actual transactions in the repo market. It is considered to be risk free because its underlying transactions used to calculate the rate are secured by U.S. Treasury securities. However, banks are free to choose other rate methods (Ameribor, BSBY, Fed Funds, Prime Rate, etc.). AFS systems are ready to support and process any chosen rate method. When will the SOFR rates be published? On March 2, 2020, the Federal Reserve Bank of New York began publishing a compounded 30-Day, 90-Day and 180-Day Average SOFR. The SOFR Averages and Index Data are available on the Federal Reserve Bank of New York’s website at https://apps.newyorkfed.org/markets/autorates/sofr-avg-ind. Additionally, daily SOFR in Arrears is available at https://apps.newyorkfed.org/markets/autorates/SOFR. When does AFS anticipate providing the LIBOR Transition Change (Requirements) Documentation? User documentation is supplied as part of the code delivery. Is there a timeline for the transition? AARC has published a Paced Transition Plan that includes specific steps and timelines designed to encourage adoption of SOFR. If you have any LIBOR transition questions or concerns, please contact Dean Snyder at DSnyder@afsvision.com.