There are currently 18 banks on the US dollar Libor panel, with the members coming from eight different countries. More than 60 per cent of the panel come from the European continent (including those outside the Eurozone in the UK and Switzerland). An additional four names are from North America and three from Japan.  If we assume that the banks that are unable to raise funding in the unsecured cash markets in London instead use as their fixing rates the levels at which they are able to raise US dollar euro commercial paper in New York, then we may get some interesting outcomes. We know from analysis of US money market fund investments (for example, published last week by Fitch Ratings) that Japanese and Canadian names have been favoured by those funds in recent weeks, and that the Swiss continue to be able to access a reasonable volume of funding. At present the two Swiss banks are setting their three month Libor rate around five basis points below the fixing rate, whilst the lone Canadian bank on the panel is submitting a rate 1.5 basis points higher. The three Japanese banks are setting their rates at an average of 2.6 basis points higher than the fixing rate. What this means is that in the absence of any physical unsecured cash deals taking place in the London market the Japanese and Canadian names could potentially submit lower Libor based upon the pricing of their commercial paper issuance levels. (This assumes that the banks on the Libor panel are the same names that the US money market funds have been buying). The three American names have been fixing Libor around one to 1.5 basis points below the fixing rate. Assuming that they are able to base their submissions off other fund-raising activities, including what funds they are raising in the United States, then it would appear to be unlikely that they will need to raise their Libor submissions, and in fact they may be able to lower them. The removal of the requirement that the Libor rate be based on the unsecured London interbank market is absolutely key here, with a wider definition likely to make it much easier for some names to justify a lower Libor input. Along with the four British banks this leaves a single German name, a single Dutch name and three French banks to consider. While money market fund investors have been reluctant to buy German paper the only German Libor panel member is Deutsche Bank, and given their global size and focus, they have largely been removed from the generalised concerns about German names. Deutsche is submitting three-month Libor around five basis points below the fixing rate, and in the absence of any dealing of their own they would probably benchmark themselves off the other good name Europeans. If they can see rates trading elsewhere and they haven't dealt themselves, then they can legitimately use the market observed rates. Much the same argument will apply to Rabobank, which is