LCH Consultation on Conversion of Outstanding Cleared USD LIBOR® Contracts

Report date

Circular No.

LCH Circular No 4206


29 April 2022


All SwapClear Users


LCH Group, and its SwapClear business, strongly supports the continuing industry-wide efforts to transition from existing benchmarks to risk-free rates (“RFRs”).

In response to the discontinuation of non-USD LIBORs at the end of 2021, and following extensive consultation with SwapClear members and clients, LCH Ltd (“LCH”) successfully converted its SwapClear Contracts[1] linked to such benchmarks into their RFR equivalents in a series of events conducted in Q4 2021.

According to the stated intention of the benchmark administrator[2], the remaining USD LIBOR benchmarks which are currently in publication are set to be discontinued from 30th June 2023. This discontinuation triggers well-established SOFR-driven fallback arrangements but also gives rise to complications and challenges.

Through this circular, LCH is issuing an invitation to all SwapClear participants to respond to a consultation regarding the treatment of outstanding cleared USD LIBOR SwapClear Contracts at or around the Index Cessation Effective Date[3] and their potential conversion into (or replacement with) corresponding SOFR-based SwapClear Contracts. A consultation document available to all SwapClear users has been published on LCH’s website, together with instructions on how to respond.

LCH strongly encourages SwapClear users to respond to this consultation and to express their opinion on the proposed approach in order to gather the widest set of feedback possible regarding next steps. LCH requires responses by 27th May 2022. Feedback received after this date may not be considered.

Any solution will be subject to risk governance review and regulatory review and/or non-objection.

Should you have any comments or questions, or if you require further information, please do not hesitate to contact


[1] “SwapClear Contract” includes an “FCM SwapClear Contract” for the purposes of this circular and the consultation. SwapClear Contract and FCM SwapClear Contract have the meanings assigned to them in the General Regulations or FCM Regulations (as applicable) and made available at (


[3] As defined in ISDA’s Fallbacks Supplement.