Comparing UK and US secondary debt trading markets, with particular reference to the LMA v LSTA recommended terms for secondary trading


Produced in partnership with Diane Roberts of Reed Smith and updated by Jacqui Allen of Mandel, Katz & Brosnan LLP
Practice notes

Comparing UK and US secondary debt trading markets, with particular reference to the LMA v LSTA recommended terms for secondary trading


Produced in partnership with Diane Roberts of Reed Smith and updated by Jacqui Allen of Mandel, Katz & Brosnan LLP

Practice notes
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The UK and US secondary (private) debt trading markets are very similar when transacted on the suite of documents issued by the Loan Market Association (lma) in the UK and by the Loan Syndications and Trading Association (LSTA) in the US.

For more information on the documentation, terms and mechanics for LMA secondary debt trades, see Practice Notes:

  1. •

    Overview of the key documentation in a typical secondary debt trade

  2. •

    Secondary debt trading—timeline of a typical trade

  3. •

    Secondary debt trading—completing the trade confirmation, and

  4. •

    Key provisions in the LMA standard terms and conditions for secondary debt trading

Historically, there has been a great deal of convergence between the two debt-trading regimes and conventions so that in most salient respects they are substantially similar. Nonetheless, the two-debt trading regimes and conventions contain some material differences as noted below.

Governing law and legal concepts

The LMA

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Jurisdiction(s):
United Kingdom
Key definition:
Par definition
What does Par mean?

The face value of a security at which it will be redeemed by the borrower at maturity

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