CLLS LIBOR Working group response to HMT Consultation Safe Harbour

This response to the Consultation has been prepared by the CLLS Financial Law Committee Working Group on LIBOR (the "Working Group"), details of which are set out in the Appendix to this letter. Being made up of legal practitioners in the financial services sector, the Working Group recognises that the transition away from the use of LIBOR creates a unique set of circumstances and welcomes the Financial Services Bill (the "Bill") and the proposed provisions which would allow the orderly cessation of a critical benchmark. The Working Group is therefore pleased to respond to the Consultation given its importance, particularly to matters of legal certainty