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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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The SEC’s Office of Compliance and Examinations (OCIE) recently announced an examination initiative focusing on registrant preparedness for the transition away from the London Interbank Offered Rate (LIBOR). OCIE intends to use the examination process to assess whether registrants are prepared for the expected discontinuation of LIBOR and the transition to an alternative reference rate.

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OCIE will review whether and how a registrant has evaluated the transition’s potential impact on the organization’s business activities, operations, services, and customers, clients and/or investors (collectively, “investors”). Specifically, OCIE will review the plans registrants have developed and steps they have taken to prepare for the LIBOR discontinuation, including, as applicable:

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Advisers should review their LIBOR transition plans and consider their effectiveness in accordance with OCIE’s latest guidance.

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Andrew J. Davalla 614.469.3353 <a href="mailto:Andrew.Davalla@ThompsonHine.com">Andrew.Davalla@ThompsonHine.com</a>

Brian Doyle-Wenger 614.469.3294 <a href="mailto:Brian.Doyle-Wenger@ThompsonHine.com">Brian.Doyle-Wenger@ThompsonHine.com</a>

This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.

This document may be considered attorney advertising in some jurisdictions.

https://admin.thompsonhine.com/wp-content/uploads/2022/04/Investment_Management_Update_-_SEC_Announces_LIBOR_Examination_Initiative.pdf

SEC Announces LIBOR Examination Initiative

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