“Tough legacy” in the context of transition away from LIBOR refers to existing LIBOR referencing contracts that are unable, before the end of 2021, to either convert to a non-LIBOR rate or be amended to add fallbacks. While significant progress has been made in relation to new contracts either referencing a risk-free rate (RFR) or incorporating fallbacks, market participants and industry bodies have flagged to regulators that there will be a number of legacy LIBOR referencing contracts without appropriate fallbacks that will continue post 2021.
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