Over the past few years, the Financial Stability Board (FSB) has been working with authorities and standard-setting bodies to develop reform proposals to enhance the robustness of interest rate benchmarks. On 5 March 2021, the UK Financial Conduct Authority (FCA) confirmed that all LIBOR settings will either cease to be provided by any administrator or no longer be representative:
immediately after 31 December 2021, in the case of all sterling, euro, Swiss franc and Japanese yen settings, and the 1-week and 2-month US dollar settings; and
immediately after 30 June 2023, in the case of the remaining US dollar settings.
As LIBOR is used extensively in the Hong Kong banking sector, the benchmark reform will have significant implications on the operations of Authorized Institutions (AIs). The related preparatory work can be substantial and complicated. In light of this, the HKMA has been engaging AIs in getting them prepared for the transition.
In Hong Kong, the Hong Kong Interbank Offered Rate (HIBOR) has been in place for many years and is still widely recognised by market participants as a credible and reliable benchmark. While the Hong Kong Dollar Overnight Index Average (HONIA) has been identified as an alternative to HIBOR, there is no plan to discontinue HIBOR. This multi-rate approach has also been adopted by many other jurisdictions.
Hong Kong banking sector’s exposures to LIBOR contracts
The HKMA has launched a regular survey to monitor the banking sector’s exposures to LIBOR contracts. As of March 2021, there were HK$4.5 trillion of assets and HK$1.3 trillion of liabilities in the Hong Kong banking system referencing LIBOR, representing about 27% and 9% respectively of the banking system’s total assets and total liabilities denominated in foreign currencies. Additionally, there were derivatives contracts involving an aggregate amount of HK$30.7 trillion in notional value referencing LIBOR. 24% of these LIBOR-linked assets and liabilities, and 7% of these derivatives contracts would mature after LIBOR’s cessation dates and did not have adequate fallback.
LIBOR transition milestones
Having regard to the developments in other financial markets and taking into account the local industry’s feedback, the HKMA and the Treasury Markets Association (TMA) jointly developed three transition milestones which AIs should endeavour to achieve. These milestones should help facilitate an orderly LIBOR transition for the banking sector as a whole.
Hong Kong banking sector’s preparedness for LIBOR transition
The Hong Kong banking sector has made good progress in preparing for the transition from LIBOR to ARRs. All AIs have developed a bank-wide transition plan, covering the following key elements:
On compliance with the transition milestones, most AIs have started to offer ARR products and included fallback provisions in new LIBOR contracts. All except a small number of AIs have adhered to ISDA’s IBOR Fallbacks Protocol to implement fallbacks for relevant legacy derivatives contracts. The International Monetary Fund also examined the Hong Kong banking sector’s readiness for the LIBOR transition in its Financial Sector Assessment Program and concluded that transition risks have been well-managed.1
With less than six months until the end of 2021 when most LIBOR settings will be discontinued, it is critical for AIs to complete their preparatory work in their LIBOR transition project. The HKMA will continue to follow up with AIs where necessary to ensure a smooth transition from LIBOR to ARRs.
1International Monetary Fund, People’s Republic of China – Hong Kong Special Administrative Region: Financial System Stability Assessment, June 2021, page 25. See https://www.imf.org/en/Publications/CR/Issues/2021/06/04/Peoples-Republic-of-China-Hong-Kong-Special-Administrative-Region-Financial-System-Stability-50197.