NAIC: Financial Analysis Solvency Tools Working Group (E) – Complex Ownership Structures (SIFMA AMG)
SIFMA AMG provided comments to the National Association of Insurance Commissioners (NAIC) on the Financial Analysis Handbook Exposure Draft.
December 7, 2021
The Honorable Nancy Pelosi
Speaker
U.S. House of Representatives
Washington, DC 20515
The Honorable Kevin McCarthy
Republican Leader
U.S. House of Representatives
Washington, DC 20515
RE: The passage of H.R. 4616, the “Adjustable Interest Rate (LIBOR) Act,” to address “tough legacy” contracts that currently reference LIBOR
Dear Speaker Pelosi and Republican Leader McCarthy:
We, the undersigned organizations, support H.R. 4616, the “Adjustable Interest Rate (LIBOR) Act,” to address “tough legacy” contracts that currently reference LIBOR. We respectfully request the House of Representatives expeditiously pass this legislation. In June 2023, all tenors of US dollar LIBOR, one of the most important financial benchmarks that underpins nearly $200 trillion in financial contracts, will cease to be published. As a result, there are trillions of dollars of hard to modify financial contracts, securities, and loans that use LIBOR – known as “tough legacy” contracts – that are unable, before this end date, to either convert to a non-LIBOR rate or amend the contracts to add adequate fallback language to another rate. Without federal legislation to address these contracts, investors, consumers, and issuers of securities may face years of uncertainty, litigation, and a change in value. This would thereby create ambiguity that would lead to a reduction in liquidity and an increase in volatility.