As has been widely communicated, on July 27, 2017, Andrew Bailey, the Chief Executive Officer of the United Kingdom’s Financial Conduct Authority (“FCA”), made an announcement that sent a shock wave through the financial markets: the London Interbank Offered Rate (“LIBOR”), the primary reference rate that underpins at least $350 trillion in global financial transactions according to the ICE Benchmark Administration, will be phased out by 2021.

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