Comments on the Comments: Responses to the FRB’s Proposed Changes to Regulation Z EFC-NCHELP

Attorney Published Article

August 30, 2022

On July 28, 2022, the Board of Governors of the Federal Reserve System published a proposed regulation to implement the Adjustable Interest Rate Act. Due to problems with LIBOR no longer being representative of the underlying borrowing costs of banks that LIBOR was intended to reflect, LIBOR is scheduled to be discontinued on June 30, 2023.