LIBOR FRB FAQ 2 – If a loan contract will automatically renew after December 31, 2021, would this be viewed as a new contract?

Compliance > Regulation Z - TILA > LIBOR Transition
Q:  If a loan contract will automatically renew after December 31, 2021, would this be viewed as a new contract?
 
A:   Yes, the automatic renewal of the loan would be viewed as a new contract because it would extend the term of an existing LIBOR contract. A Board-supervised institution should take steps to address such automatic renewals.
 

 
This Q&A was created based on information from the Federal Reserve’s website (which may be updated from time to time) that provides Answers to Frequently Asked Questions on the Transition Away from LIBOR.  This information may be found here:  https://www.federalreserve.gov/supervisionreg/srletters/SR2112a2.pdf
 

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