LIBOR Decommissioning Program

Most institutions simply do not know what LIBOR fallback language exists in their hundreds of thousands of relevant contracts as these are unstructured documents which are not machine-readable. Given the scale/complexity of the effort and time constraints, a manual approach to identifying the contracts that require review/repapering will not scale. Furthermore, from a regulatory and legal perspective, a well-controlled, sustainable LIBOR Decommissioning Program requires evidence-based data lineage, documented audit trails and transparent logic.

Pendo Systems and Vuram have partnered together to provide a solution that leverages a hybrid approach to combine two distinct software capabilities to serve as the centralized, sustainable repository for all LIBOR Decommissioning work product and communications. This enables the legal analysis to create the waterfall of logic of actions for each category of fallback language while significantly reducing non-value manual work to accelerate and strengthen the LIBOR Decommissioning Program.

  • Pendo: Creates a single data layer, combining contractual data (e.g. contract ID, fallback rate / terms / triggers, consent requirements, etc.) and deal attributes (e.g. customer / contract ID, reference rate, principal, maturity, spread, etc.) from unstructured documents and transforms it into a machine-readable format.
  • Vuram: Utilizes Appian’s BPM capabilities to case manage structured contractual and product data to enable linkage capability, completeness checks, KPI reporting, workflow forecasting and PMO reporting within and enterprise (LOB, products) and across the industry. Accelerates the contract amendment process by including drop down menus with prepopulated fallback replacement language by authoritative agency (LSTA, LMA, ISDA) and by product (credit agreement, indenture, swap, etc.)

Key Features and Functionality:


  • Ingests directly from Files/Folders, Document Management Systems (e.g. FileNet, Documentum, SharePoint), vendor systems and structured databases.
  • Indexes every word in each document making them immediately searchable for LIBOR attributes at both the document level and for global search across all documents.
  • Creates the framework to enable machine readability, data lineage and audit trail across the corpus of documents.
  • Provides the user with the ability to create a data shopping list to surface and extract the critical few or hundreds of data elements needed and provides the user with easy to read visual confirmations for each data element mapped.
  • Generates a fully customizable structured data set for export via CSV, JSON, or API.
  • Allows for future reuse of the data index to add new mappings and real-time search.

Vuram's Appian Application:

  • Receives the Pendo data set and customizable rules that identify if the contract has LIBOR terms or needs to be sent to a PMO and Attorney queue for further processing.
  • Provides customizable dashboards for each role in the LIBOR Decommissioning Program (e.g. Admin Agent, PMO, Primary Lender, Legal). These dashboards provide deal statistics and reports, deal review ageing, a LIBOR Fallback thumbnail screen and link to original and referenced documents.
  • Provides the PMO user with a “digital PMO assistant” to eliminate the assembly of PMO artifacts and reporting thereby allowing this critical function to focus on value-add activities
  • Provides information about all the deals in the Vertical Record (e.g. all documents processed in the system and key attributes such as deal value, lender, line of business with appropriate filters).
  • Provides a Deal Status Report which includes key stats on all deals in the system and deal completion metrics
  • Provides for the automatic generation of all related correspondence (e.g. amendments, disclosures, e-mails).