The Beginning of the End of the End: Transitioning Loans and Derivatives from USD LIBOR in 2021
Client Alert | 1 min read | 03.10.21
On March 5, the UK’s Financial Conduct Authority announced the dates on which USD and other LIBOR settings will cease to be published, officially marking the long-anticipated beginning of the end of a multi-year process to terminate LIBOR and transition markets to new benchmark rates.
In this client alert, Julia Lu and John A. Clark compare model USD LIBOR fallback approaches that have been promulgated by policymakers and industry leaders in the U.S. syndicated loan market, on the one hand, and the over-the-counter derivatives market, on the other, and discuss two alternative strategies for market participants seeking to minimize basis risk arising from different fallback approaches.
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Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
