Management’s Discussion and Analysis
Section IX: Risk Management
IBRD MANAGEMENT’S DISCUSSION AND ANALYSIS: JUNE 30, 2021 55
Alternative Reference Rate
In July 2017, the Financial Conduct Authority (FCA), the regulator of LIBOR, announced that it will no longer compel
panel banks to submit rates required to calculate LIBOR after December 31, 2021 and, therefore, market participants,
including IBRD and its borrowers need to move to alternative reference rates because the availability of LIBOR after
this date is not a certainty. In March 2021, the FCA confirmed that all the LIBOR settings will either cease to be
provided by any administrator or no longer be representative, as follows:
• All sterling, euro, Swiss franc and Japanese yen LIBOR settings, and the 1-week and 2-month USD LIBOR
settings, will cease immediately following publication on December 31, 2021.
• All remaining USD LIBOR settings, including the 6-month USD LIBOR used as the reference rate for IBRD
loans, will cease immediately following its publication on June 30, 2023.
Despite the extension of the publication of certain USD LIBOR rates to June 30, 2023, the regulators’ guidance
remains that LIBOR should not be used for new contracts after 2021. In consideration of the regulatory guidance and
in preparations for the global markets’ transition away from LIBOR, IBRD has taken important steps to facilitate a
smooth and orderly transition of its financial instruments effected by alternative reference rates.
IBRD previously completed an initial impact assessment of its exposure, both quantitatively and qualitatively, to
LIBOR and developed an implementation roadmap for the LIBOR transition. IBRD is actively working through this
transition from multiple perspectives: lending, funding, accounting, operations, information technology, liquidity
investing, risk and legal, considering the portfolio of existing loans and other instruments that use LIBOR as a
benchmark. In FY20, the Board endorsed an omnibus amendment process with borrowers for loan agreements to
address the replacement of LIBOR, allowing IBRD to maintain and preserve the pre-existing relationship between its
funding costs and lending rates and maintain the principles of fairness and equivalence for any replaced reference rate.
The contract amendments will enable similar treatment to all loans by bringing the fallback provisions related to
changes in the reference rate in the General Conditions into conformity with the revised General Conditions of
December 2018. The new language permits IBRD to transition the interest rate to alternative reference rates when a
suitable alternative is available, and it is appropriate to do so. To date, IBRD has made significant progress in securing
counter-signature of the omnibus amendments from borrowers. IBRD is also using pre-existing provisions in loan
agreements to implement these changes.
In addition, as the market undergoes fundamental changes due to the transition to alternative reference rates, as part
of its interest rate risk management, on January 26, 2021, the Board approved a suspension of the offering of loans on
fixed spread terms, as well as suspension of a related conversion feature from the variable spread terms to fixed spread
terms, effective from April 1, 2021. An existing feature to permit fixing of the reference rate in loans with variable
spread terms remains available.
In July, 2021, the Board approved offering new loans with new alternative reference rates and ceasing to offer LIBOR
based loans effective January 1, 2022; and the switch-over of existing loans beginning in January 2022 for all variable
spread and non-USD fixed spread loans and beginning in July 2023 for the remaining USD fixed spread loans (see
Table 14). Careful consideration was given to the regulatory guidance, relevant provisions in IBRD’s General
Conditions and loan agreements, asset liability management (ALM) needs, as well as borrower implications. As a
result of the different characteristics of the new market reference rates and LIBOR, and the implications of a staggered
LIBOR cessation timetable, there will be changes to the current loan processes including billing and cost-pass through
computation methodologies used for lending rates. IBRD will continue to work with key stakeholders, including
internal subject matter experts, senior management, borrowers, industry groups and other market participants, to
mitigate potential financial and operational risks to which IBRD is exposed and to ensure an orderly transition to the
alternative reference rates. IBRD is managing the transition prudently and in a cost-effective manner.
Exchange Rate Risk
IBRD mainly holds its assets and liabilities in U.S. dollars and euro. However, the reported levels of its assets,
liabilities, income, and expenses in the financial statements are affected by exchange rate movements in all the
currencies in which IBRD transacts, relative to its reporting currency, the U.S. dollar. IBRD’s functional currencies
are the U.S. dollar and euro. Currency translation adjustments relating to euro-denominated balances are reflected in
other comprehensive income, a component of equity. Currency translation adjustments relating to non-euro
denominated balances (non-functional currencies) are reported in the Statement of Income. While IBRD’s equity