On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an “IBOR”) and toward alternative benchmarks. The letters responded to requests for relief made by the Alternative Reference Rates Committee (the “ARRC”), the group convened by the Federal Reserve to facilitate the transition away from USD LIBOR, the IBOR generally used for United States dollars, to the new reference rate chosen by the ARRC, known as the secured overnight financing rate, or SOFR.

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