Q: Does the LIBOR-Specific Rate Reevaluation Exception apply if the card issuer transitions from LIBOR prior to April 1, 2022?
A: No. The LIBOR-Specific Rate Reevaluation Exception provided for in the LIBOR Transition Rule is only available beginning on April 1, 2022.
If the card issuer completes the transition prior to April 1, 2022, the condition that it identify a replacement index in accordance the LIBOR Transition Rule’s Unavailable or LIBOR-Specific Provisions cannot be complied with, as they are not effective until April 1, 2022. Comment 59(h)-1. In such a case, the card issuer must complete the rate reevaluations. See LIBOR Credit Card FAQ 13 for more information about how to complete the rate reevaluations when LIBOR is unavailable.