Case Study

LIBOR Cessation Transition Planning & Management

Risk Data


Large Brokerage Trading Firm


Risk Analytics & Reporting, Regulatory Program Compliance, Business Intelligence & Reporting

Project Overview

With the London Interbank Offered Rate (LIBOR) being phased out as an interest-rate benchmark, securities with LIBOR-based contracts needed to transition to alternative rates such as the Secured Overnight Finance Rate (SOFR). Certain LIBOR-based securities, designated as “Tough Legacy”, pose a higher risk to holders due to a lack of adequate fallback provisions. In preparation for the LIBOR cessation, the Client’s Internal Audit group issued an action plan, prompting the risk organization to seek a partner to effectively implement this plan and ensure that the company was prepared for the transition. The Client required a strategic project plan with proper governance to ensure operational readiness, customer exposure management, and effective communication.  Reference Point (RP) was chosen to lead this initiative, with the challenge of balancing tight timeframes, constrained resources and ensuring a positive customer experience. The program involved over 100 stakeholders across diverse bank areas including product management, legal, compliance, risk, marketing, data & analytics, sales and service, and over ten distinct technology teams.


  • RP deployed a team to lead the program and develop a strategic approach to meet the Client’s objectives. The Initiative involved managing the program and its underlying projects, performing business analysis, writing business requirements, creating and executing user acceptance test plans, preparing management updates, providing advisory services and operationalizing key processes.
  • The RP team designed and implemented a Tableau-based client exposure report, which involved mapping out a complex data flow with relevant LIBOR attributes, performing rigorous testing, and establishing a monthly distribution process.
  • The RP team developed a communication strategy to raise awareness of LIBOR cessation risks, including a visual indicator on the portfolio holdings page for any LIBOR-based position, a warning message for customers across various trading platforms attempting to purchase a LIBOR based security, and an informational page on the LIBOR transition for clients accessing the trading platform.
  • RP collaborated with technology and product management teams to assess the operational readiness of applications and vendor systems, end user computing tools and models that could have LIBOR dependencies, and to remediate any with required changes.
  • RP managed a process to block client purchases of high-risk “Tough Legacy” LIBOR-linked securities.


  • RP created a comprehensive project plan addressing operational readiness, communication and client exposure resulting in the closure of the Internal Audit action plan.
  • Despite a compressed timeframe, RP led the implementation and operationalization of the Customer Exposure report and spearheaded all necessary changes to the customer-facing brokerage trading systems.
  • Operational readiness was fully achieved with any necessary remediation performed on systems, end user computing tools, and models.
  • Serving as the Subject Matter Expert for the LIBOR cessation initiative, RP presented monthly at the LIBOR Risk Steering Committee and provided advisory services throughout the program, including advice on client communication and guidance on technology implementations.
  • Drawing on our industry experience, RP effectively steered this program to success, fulfilling the Client's objectives and enhancing their readiness for the LIBOR transition.

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