And it’s true that the regulatory authorities have stressed that firms’ boards and executives must take ownership of the transition and its key milestones, through ‘Dear CEO’4 and ‘Dear Senior Manager’5 letters, and through direct supervisory  1  You can see this vividly in the charts at: www.theice.com/iba/historical-data www.bankofengland.co.uk/-/media/boe/files/markets/benchmarks/rfr/rfrwgs-2020-priorities-and-milestones.pdf This target refers to products maturing beyond 2021 4 Dear CEO letter: www.bankofengland.co.uk/prudential-regulation/letter/2018/firms-preparations-for-transition-from-libor-to-risk-freerates and feedback: www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/publication/2019/firms-preparations-for-transitionfrom-libor-to-risk-free-rates.pdf 5 www.bankofengland.co.uk/prudential-regulation/letter/2020/next-steps-on-libor-transition 2 3  2  All speeches are available online at www.bankofengland.co.uk/news/speeches  2  engagement. The FCA has set out how it will exercise its powers of life and death over LIBOR, including the critical judgment on representativeness.6 And the Bank’s Financial Policy Committee (FPC) has said that it will consider using other policy and supervisory tools to encourage transition if progress is too slow. 7  FIGURE 1: Sterling Risk Free Rate Working Group roadmap for 2020  But the public sector has ‘carrots’ too – and we are doing at least as much to encourage and enable sterling transition as we are to enforce it. The Bank of England has been producing SONIA, the market’s chosen risk-free rate, on a daily basis since 2018. With the FCA, we provide the secretariat for the Working Group, helping market participants to identify common goals and targets. We regularly gather structured market-wide information on progress – first through the ‘Dear CEO’ process and more recently by initiating a regular data collection exercise – and we use it to provide feedback on risks and share good practices.
The chronic lack of underlying transactions1 means that LIBOR is simply too fragile a benchmark to support a sustainable business model – indeed its continued existence poses material risks to financial stability, both in the UK and globally. That’s why in the race to say goodbye to LIBOR, it is firms’ own business leads, project managers and subject matter experts that are designing and driving the cars, supplying the tyres, and running the pit crews – re-engineering systems, innovating new financial products and services, and delivering them to customers. But it’s not just a firm-by-firm effort: it’s cross-market too. Under the leadership of Tushar Morzaria, Barclays’ CFO, the sterling Risk Free Rate Working Group and its various offshoots have brought together over 200 industry experts to solve collective problems. That includes setting the route map to the chequered flag – the latest version of which was released in January (Figure 1).2 Amongst many important milestones on that map, the most important is to cease issuance of term sterling LIBOR-linked cash products by the third quarter of 2020. 3  The increased focus and energy from sterling market participants this year is palpable. But they cannot run this race alone. As track marshals and safety officials, the Bank of England and FCA also have important roles to play – and we are using all the tools at our disposal in that quest. Understandably, perhaps, focus often alights on the ‘sticks’ we can wield.