Published Work
BAB Crypto & Regulation
A belated reaction to a really outstanding Executive Roundtable provided by British American Business on Crypto Assets and Regulation. Kudos for BAB’s convening powers as we had the Acting Comptroller of the Currrency, head of the OCC – Michael Hsu; the head of...
Fed Supervision LIBOR
This is the Joint Statement from Federal Reserve, OCC, FDIC and CFPB on LIBOR. No surprises, but continued reinforcement that this will be a top-of-agenda bank supervisory issue in 2022. They will question why you renewed contracts with a defunct LIBOR benchmark. And...
LIBOR Transition slow to progress in the Loan Market
Broyd Partners helped William Shaw at Bloomberg with this article. Loan market traction is slow, but we believe will accelerate now. Loan IQ - the Finastra deal booking system that is used by over 70% of the syndicated loan market - being ready to book the...
A Regulatory Framework for Crypto
There has been a lot of noise and several prominent announcements over the regulation of crypto and digital asset supporting firms in the last nine months. These include SEC Chair Gary Gensler's recent comments that digital assets are "rife with fraud, scams, and...
How do Markets desks really perform?
Almost every firm with a trading-desk capability periodically reviews the performance of their sales and trading teams. Typically, this is done using internal 2nd line (risk) and 3rd line (audit) resources at regular intervals following a routine process of checking...
Do you have the right end-date for LIBOR Transition?
June 2019
LIBOR will cease to exist as a ‘Benchmark’ at end of 2021. The Benchmark’s regulator, the FCA, has been very clear and consistent in this message.
The process to replace IBORs with Risk Free Reference Rates (RFRs)…
Follow the FCA on LIBOR Transition II
December 2019
In LIBOR transition I have always thought it most appropriate to listen first to the FCA and Edwin-Schooling Latter. There are a lot of opinions out there, but this is the regulator of the LIBOR Benchmark, and one with enhanced powers. When thinking of the USA and the…
LIBOR impact on new issuance of securitizations (RMBS, CMBS, ABS, CLOs)
December 2019
Most contracts that reference LIBOR include a ‘fallback’ clause, which defines the rate that the contract would fall back to if LIBOR were no longer available…
The FX Code of Conduct – a new priority
January 2020
The expectation is that beginning in 2020, there will be a US regulatory focus (driven by the Federal Reserve Bank and the UK’s Financial Conduct Authority) on Banks and Financial Services firms evidencing proper implementation and…