Yesterday the Bank of England and the FCA (and the RFR working group) issued at least six publications, making sure the market is in no doubt about what they expect during 2020. The most interesting of these publications for lawyers is “Use Cases of Benchmark Rates: Compounded in Arrears, Term Rate and Further Alternatives”. As well as emphasizing messages that readers will know well, there is a new key date: 2 March 2020. On this date they are “encouraging” the GBP interest swap market to start doing “the greater part” of new swaps by reference to SONIA, not LIBOR. It seems that the traded monthly notional value of the SONIA swaps market has now grown to over GBP 4.5 tr, which is about the same as for GBP LIBOR, and the trend is towards SONIA. This has big implications for REF and any other loans with interest hedging, because once the main volume is based on SONIA, borrowers will want to avoid the basis risk, and since what they really want is fixed rate finance, those loans are going to switch to being done over backwards-looking SONIA. More generally, as volumes in SONIA grow and LIBOR shrinks, the SONIA market spreads should become tighter, meaning better pricing for borrowers than off LIBOR. The big change – which we as lawyers will not notice – will be when the big dealers move to providing executable streamed SONIA-based quotes; at the moment, you have to ask for a quote. That will happen over the next few weeks.