You may be aware that reference rates and indices which are deemed to be "benchmarks" (including interbank offered rate (IBOR) such as the London Interbank Offered Rate (LIBOR)) are the subject of ongoing international and national regulatory discussions and proposals for reform. Some of these reforms are already effective whilst others are still to be implemented. These reforms may cause such benchmarks to perform differently than in the past, to disappear entirely, or have other consequences which cannot be predicted.
As an example of such benchmark reforms, the UK Financial Conduct Authority (FCA), who regulates LIBOR, has stated that it will no longer compel banks to submit rates for the calculation of LIBOR after the end of 2021. The US Federal Reserve and other regulators of IBORs have also taken various measures to move market participants away from IBORs within set timelines. As a result, the continuation of LIBOR and other IBORs on the current basis cannot be guaranteed after 31 December 2021.
Even if certain benchmark rates might continue to be published, changes to their methodology or restrictions on or discouragement of their use may mean that they cease to be representative of the underlying market and economic reality that a benchmark is intended to measure as required by applicable law or regulation or otherwise cease to be appropriate for use for certain types of financial contracts or financial instruments that you have entered into with Abu Dhabi Commercial Bank PJSC or any of our affiliates (collectively, ADCB).