ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Commercial Lending

Time to Test: Surveying Post-Libor Options for Banks

March 16, 2020
Reading Time: 11 mins read
A Risk Manager’s Guide to the Reference Rate Transition

By Paul Noring 

The clock is ticking down to the end of 2021, when the London Interbank Offered Rate is no longer guaranteed to be available as a reference rate. With Libor underpinning close to $200 trillion in financial contracts in the United States alone (and more globally), global regulators and banks alike have been eager to find replacements for Libor that can serve as a suitable benchmark rate across all major currencies.  

In the U.S., the Alternative Reference Rate Committee—a group of market participants convened by the Federal Reserve—has selected the Secured Overnight Financing Rate as its preferred Libor heir, and the ARRC is currently creating resources and fallback language to help banks understand the new rate and transition their contracts to SOFR. Getting there by Jan. 1, 2022, will require a herculean effort to ensure a smooth transition.  

In the meantime, market participants may find that other alternative benchmarks suit their needs better for certain products. Now is the time for banks to analyze the reference rate scene and begin making their transition plans. 

SOFR: the ARRC’s preferred alternative

SOFR (see table 1) is a secured rate and represents the costs of funds in the overnight repurchase markets. Whereas Libor is an unsecured rate with a dynamic credit spread, SOFR is a secured rate there is a view that in times of significant market stress that rate will decrease and borrowers will pay a lower rate to banks, whereas banks’ cost of funds will rise. This could compound safety and soundness issues by decreasing net interest margin at the same time there is significant credit deterioration. This concern was highlighted by two separate groups of regional and midsize banks in letters to the regulatory agencies.  

Table 1: Key Differences Between SOFR and Libor 

SOFR  Libor 
Secured rate  Unsecured 
Currently only an overnight rate  Up to seven tenors, extending up to one year 
Interest most likely calculated in arrears  Interest calculated in advance 
High daily volatility given issues in repurchase market  Low daily volatility 
Based on actual transactions  More of a hypothetical rate (limited transactions) 


Other key issues include those highlighted in table 1. 
One of which that has been discussed at length among participants responsible for conversion efforts are the operational challenges of moving to SOFR. Specifically, for loans currently rely on an advanced Libor rate—that is, the rate on the reset date will be the rate for the next period, in contrast with SOFR—the ARRC is moving toward the opposite approach where an in-arrears calculation may prevail. If this approach is adopted as expected, rates for the period would only be known at the end of the period. Moving to an in arrears calculation approach will require massive changes to current lending and borrowing processes and systems.  

 SOFR also poses challenges related to its volatility compared to Libor and other alternative benchmarks. Since SOFR is tied to repo agreement lending, the rate has also experienced increased volatility particularly around quarter-end and large treasury auctions (see figure 1). For instance, certain transactions exceeded a 9 percent overnight rate in September 2019, and the Federal Reserve had to step in with highly public market–stabilizing transactions in order to bring the rate into a more reasonable range. SOFR as a replacement for Libor in the derivatives market is going more smoothly. But one may not fit all for consumer and commercial lending products.  

 Figure 1 – SOFR Rates 


 Other alternatives 

Three possible alternatives have emerged, each of which has—unlike SOFR—a dynamic credit spread. None is currently an ideal replacement, but all have significant promise. 

  • Ameribor. This new interest rate benchmark created by the American Financial Exchange reflects the actual unsecured borrowing costs of over 1,000 American banks and financial institutions. Transaction volume has steadily increased, and the rate has proved to be much more stable than SOFR even during periods of quarterly volatility. 
  • Bank Yield Index. To be published by ICE, which also publishes Libor, it is a forward-looking, credit-sensitive benchmark designed specifically as a potential replacement for Libor for U.S. dollar lending activity. The index seeks to incorporate some of the key properties of Libor that cash market participants have said they would like to retain in a U.S. dollar lending benchmark.
  • Commercial Paper Rates. The Federal Reserve Board of Governors publishes daily commercial paper rates derived from data supplied by the Depository Trust and Clearing Corporation, a national clearinghouse for the settlement of securities trades and a custodian for securities. DTCC performs these functions for almost all activity in the domestic CP market. 

Some of the advantages and limitations of each of these alternatives is highlighted in table 2.

Table 2. Alternative Rates Advantages and Limitations 

Rate  Advantages  Limitations 
Ameribor  IOSCO–compliant 

 

True interbank lending rate 

 

Good market depth, with more than 100 banks participating daily with as much as $3 billion in daily transactional activity 

 

Regulated futures contract currently trades and ability to obtain cash flow hedge accounting 

 

To date, predominantly an overnight rate, with no meaningful term structure / forward rates 

 

Activity to date has been with midsize and regional banks; not yet used by top 30 or global internationally active banks 

 

ICE Bank Yield Index  Administered by a premier global exchange 

 

Specifically designed to measure the average yields at which investors willing to invest U.S. dollar funds over on-month, three-month and six-month periods on a wholesale, senior, unsecured basis in large internationally active banks 

 

Currently, not IOSCO–compliant 

 

Methodology was fluid during 2019; changed several times 

 

To date, only test publication of rates; unlike Ameribor or actual Commercial Paper issuances, no transactions tied to the rate 

 

 

Commercial Paper Rates  Published daily for AA financials by the Federal Reserve Board of Governors  

 

Derived from actual transaction data supplied by DTCC  

 

Forward looking with term structure 

Currently, not IOSCO–compliant 

 

On certain dates, trade data maybe insufficient to support calculation of a particular rate 

 

Includes all financials not just inter-bank lending 

 

Primary purchasers of CP are money market funds (therefore not interbank lending or borrowing) 

  

 

With global regulators remaining adamant that banks should plan for a Libor cessation after 2021, two things are crystal clear about the replacement rate for commercial and consumer loans. First, many market participants are looking for a dynamic credit spread to ensure the safety and soundness of all but the largest U.S. banks; and second, it must be a forward-looking rate, as there is absolutely no way all commercial and consumer loan systems and processes can be changed in time to avoid material operational issues. Since time is of the essence, any existing and new working groups formed to study this issue should not delay. With emergent alternatives besides SOFR, market participants should start or expand their testing of the waters with actual transactions tied to these alternative rates.  

 Paul Noring is a managing director who leads Berkeley Research Group’s financial institution advisory practice, where he is currently focused on supporting clients with Libor transition activities.  

Tags: LiborReference rates
ShareTweetPin

Related Posts

FCC grants ABA-requested extension of ‘revoke all’ rule’s effective date

FCC grants ABA-requested extension of ‘revoke all’ rule’s effective date

Compliance and Risk
January 6, 2026

The FCC issued an order extending the effective date of the “revoke all” rule from April 11, 2026, to Jan. 31, 2027. Under the revoke all rule, a bank or other business is required to treat a consumer’s...

ABA urges FCC to modernize calling rules, strengthen fraud protections

ABA, associations support TCPA reform, urge action by FCC to combat fraud

Compliance and Risk
January 5, 2026

ABA led a group of eight financial trade associations in expressing support for proposals to the Federal Communications Commission that would adopt several requests to modernize the FCC’s Telephone Consumer Protection Act rules.

Off the map: Top bank risks for 2026

Off the map: Top bank risks for 2026

Compliance and Risk
January 5, 2026

New risks, uncertain territory make risk management a perilous journey in the new year.

ABA files amicus brief urging Eighth Circuit to reverse district court’s dismissal of NSF fee lawsuit

ABA offers changes to FDIC, OCC proposed safety and soundness rules

Community Banking
December 29, 2025

ABA suggested changes for the agencies' proposed rule regarding unsafe or unsound practices, as well as revisions to the supervisory framework for issuing matters requiring attention and other supervisory communications.

OCC proposes to cite federal preemption of state interest-on-escrow laws

OCC proposes to cite federal preemption of state interest-on-escrow laws

Compliance and Risk
December 23, 2025

The OCC is proposing two rules to clarify that national banks are exempt from state laws regulating real estate escrow accounts. ABA welcomed the proposals.

OCC to merge community bank, large bank supervision departments

OCC proposes to raise heightened standards threshold for banks

Compliance and Risk
December 23, 2025

The OCC is proposing to raise the threshold for which its heightened supervisory standards apply to banks from $50 billion to $700 billion in assets.

NEWSBYTES

FCC grants ABA-requested extension of ‘revoke all’ rule’s effective date

January 6, 2026

Bank acquisitions announced in six states

January 6, 2026

Rep. LaMalfa dies at age 65

January 6, 2026

SPONSORED CONTENT

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

November 1, 2025
5 FedNow®  Service Developments You May Have Missed

5 FedNow® Service Developments You May Have Missed

October 31, 2025

Cash, Security, and Resilience in a Digital-First Economy

October 20, 2025
Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

October 1, 2025

PODCASTS

Podcast: Cybersecurity in a mobile-first banking landscape

December 18, 2025

Podcast: The 2026 outlook for bank M&A

December 11, 2025

Podcast: The outlook for tech-forward community banking

December 4, 2025

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.