LIBOR CFPB FAQ All Products 4 – Are there other resources for developing a LIBOR transition plan that help to mitigate compliance risk?

Compliance > Regulation Z - TILA > LIBOR Transition
Q:  Are there other resources for developing a LIBOR transition plan that help to mitigate compliance risk?
 
A:   Yes. Public and private sector groups have developed resources to assist in planning and implementing the LIBOR transition.

The Federal Financial Institutions Examination Council (FFIEC) has issued a joint statement identifying some of the types of risks entities should consider as they develop their transition plan and providing information about preparing for supervisory examinations. The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation also issued a joint statement on reference rates for loans, providing further guidance on the transition away from LIBOR. Additionally, the Bureau has joined an interagency statement on managing the LIBOR transition.

The ARRC has also developed several resources to assist industry in the transition, available here. For example, the ARRC has published recommended best practices for consumer loans, available here and released a summary of its spread-adjusted fallback recommendations available here. For ARMs and for Private Student Loans specifically, the ARRC has also published resource guides to help creditors identify actions needed to plan for the transition.

Further, some private organizations are providing resources to assist in transition planning. For example, some investors, such as Fannie Mae and Freddie Mac have provided a transition “playbook” for their stakeholders. Additionally, some trade organizations have also developed materials, webinars, checklists, and other preparation tools. For example, some are publishing notices members may voluntarily provide to their consumers to help provide more notification for when and how those consumers’ accounts will be impacted by the transition. Trade organizations may offer these resources for free or for a membership fee.
 
 
This Q&A was created based on information from the Consumer Financial Protection Bureau’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://files.consumerfinance.gov/f/documents/cfpb_libor-transition_faqs.pdf
 

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