The FCA’s head of markets policy, Edwin Latter, warned the market to get a move on before the end of 2021 and transition to new rates, and not risk being caught out, in a speech on 6th June. “If you are an authorised firm here in the UK, you can expect your supervisors to be coming along and asking you to demonstrate to them that you have addressed those risks… “Transition does need to happen and you do need to have done, before 2021, whatever is necessary to move away from Libor”. Following a similar comment from the BOE last week, described this yesterday as a “hardening of LIBOR transition rhetoric”. But transition to what? We at DLA Piper haven’t seen it happening yet, and have seen deals going out more than 5 years being done based on LIBOR plus the usual fallback, because the alternatives remain unknown. ISDA will consult this month. It should be clearer by the Autumn.