Yesterday, ICE Benchmark Administration Limited (“IBA”), the benchmark administrator for the U.S. Dollar (“USD”) London Interbank Offered Rate (“LIBOR”), announced a proposal to extend the publication of the most commonly used USD LIBOR settings until June 30, 2023. In light of IBA’s proposal, in an interagency statement, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued guidance (the “Guidance”) strongly encouraging banks to cease entering into “new contracts” that use USD LIBOR as a reference rate “as soon as practicable and in any event by December 31, 2021”; only in “limited circumstances” will it be appropriate for banks to enter into new contracts referencing USD LIBOR after December 31, 2021. Both the Federal Reserve and the U.K. Financial Conduct Authority (the “FCA”), which supervises IBA under the Benchmark Regulation, issued statements supporting IBA’s proposal, which, combined with the Guidance, they described as facilitating an orderly transition away from USD LIBOR.