On January 21, 2020, the Alternative Reference Rates Committee
("ARRC") of the Federal Reserve Board launched a consultation seeking feedback from
market participants on ARRC's recommended spread adjustment
methodologies for cash products referencing USD LIBOR. The
consultation was titled "ARRC Consultation on
Spread-Adjustment Methodologies for Fallbacks in Cash Products
Referencing USD LIBOR" (the "Consultation").
The ARRC-recommended spread adjustment methodologies for the
cash products are intended to be used in connection with USD LIBOR
contracts that have incorporated previous ARRC-recommended
hardwired fallback language that provides for a fallback rate based
on the secured overnight financing rate ("SOFR") and the
applicable spread adjustment. The purpose of the spread adjustment
is to reduce the economic impact of shifting from an unsecured rate
to a rate that is nearly risk-free (e.g., because LIBOR
includes bank credit risk, it is likely to be higher than a