On December 18, 2019, the staffs of the Division of Swap Dealer
and Intermediary Oversight ("DSIO"),1 the
Division of Market Oversight ("DMO")2, and
the Division of Clearing and Risk
("DCR")3 of the Commodity Futures Trading
Commission ("CFTC") each released
no-action letters (collectively, the "CFTC
Letters") that provide relief to market participants
in connection with the industry-wide initiative to transition swaps
that reference the London Interbank Offered Rate
("LIBOR") and other interbank offered
rates ("IBORs") to swaps that reference
alternative risk-free reference rates.4
The CFTC Letters respond to a request by the Alternative
Reference Rates Committee ("ARRC")5 on
behalf of its members subject to certain CFTC regulations to
address issues that will result from amendments made by market
participants to their swap documentation to either (i) include
fallback language to address what will happen when LIBOR or another
IBOR ceases to exist (or is deemed to
