ISDA Publishes IBOR Consultation Paper

On July 12, the International Swaps and Derivatives Association, Inc. ("ISDA") initiated a market-wide consultation (the "Consultation")^[1] on technical issues related to new benchmark fallbacks for derivatives referencing certain interbank offered rates, or IBORs, in response to the expected discontinuance of the publication of those IBORs at the end of 2021.^[2] The purpose of the Consultation is to ease the transition of the derivatives market from referencing existing IBOR rates to alternative risk-free-rates ("RFRs") that have been identified as part of the global benchmark reforms. These RFRs are intended to be based on robust and highly liquid underlying markets that, unlike the relevant IBORs, do not require and are not based on submissions from panel banks or others.