In this report, we assess Treasury Secretary Mnuchin’s appearance today before HFSC in his capacity as FSOC Chair.  Standing by the regulators’ view that there are only two inevitabilities – death and LIBOR transition – Mr. Mnuchin for the first time indicated that Congress may need to pass legislation to mandate transitional contractual provisions to ensure a smooth transition.  Incoming Capital Markets Subcommittee Chairman Sherman (D-CA) demanded that Treasury let him know no later than January if legislation is indeed necessary.

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