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ARTICLE · 07 OCTOBER 2020

DOJ Completes Review Of ISDA IBOR Fallbacks

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The DOJ's Antitrust Division concluded a review of ISDA form amendments to provide for fallbacks to interbank offered rates.

United StatesFinance and Banking
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The DOJ's Antitrust Division (the "Division") concluded a review of ISDA form amendments to provide for fallbacks to interbank offered rates ("IBORs").

The Division found that that the proposed amendments are unlikely to harm competition "based on the representations in ISDA's letter request, including its description of certain safeguards," such as making the selection of fallback rates voluntary.

As ISDA previously noted, ISDA's launch of the IBOR Fallbacks Protocol and IBOR Fallbacks Supplement is contingent on receiving a positive business review letter from the DOJ. Assistant Attorney General Makan Delrahim said: "ISDA's process, including its cooperation with government regulators and its consultation-driven process for obtaining feedback from industry participants, has had the effect of clarifying the practical issues involved in planning for when LIBOR and other IBORs are no longer available and preparing for a smooth transition away from IBORs to other

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