Transitioning from Interbank Offered Rates (IBORs) to new Risk Free Rates (RFRs)* - GFMA

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Transitioning from Interbank Offered Rates
(IBORs) to new Risk Free Rates (RFRs)*
September 2019

In recent years, international and domestic authorities alike have actively     These documents have been updated from their previous versions (April
worked with the private sector to address LIBOR’s shortcomings and to           2019) to include rates for the Australian dollar, Canadian dollar, Hong
find alternative rates. In 2013, the International Organization of Securities   Kong dollar and Singapore dollar in addition to the currencies included in
Commissions (IOSCO) developed an international set of principles                the initial documents (Japanese yen, Euro, UK pound sterling, U.S. dollar
for financial benchmarks. These principles—which include 19 specific            and Swiss franc).
standards across governance, benchmark quality, methodology, and
                                                                                The information contained herein is based on the work of the FSB
accountability—have emerged as the international standard. IOSCO has
                                                                                through the OSSG as well as other publicly available information. For
rightly focused on tying benchmarks more closely to observable, arms-
                                                                                ongoing IBOR transition updates, please reference the individual central
length transactions.
                                                                                bank working groups:
The Financial Stability Board (FSB) and its members have published
                                                                                • Japanese yen: Study Group on Risk-Free Reference Rates and the
proposals, plans, and timelines for reference rate reform and have
                                                                                  Bank of Japan Cross-Industry Committee on Japanese Yen Interest
promoted the strengthening of the major interest rate benchmarks. The
                                                                                  Rate Benchmarks
FSB and its members have been carrying out work on the development
and introduction of alternative benchmarks, developing a plan to                • Euro: Working Group on Euro Risk-Free Rates
accomplish a transition to new benchmarks, encouraging work by the
private sector on contract robustness, and reporting regularly on the           • UK pound sterling: Working Group on Sterling Risk-Free Rates
progress made.
                                                                                • U.S. dollar: Alternative Reference Rates Committee
To aid in the awareness of the IBOR transition processes impacting
                                                                                • Swiss franc: National Working Group on Swiss Franc Reference Rates
globally-active financial institutions, the Global Financial Markets
Association (GFMA) has created the following documents outlining the               ustralian dollar: Reserve Bank of Australia Market Operations Resources
                                                                                • A
various parts and players. This information is organized into the enclosed
three products:                                                                 • Canadian dollar: Canadian Alternative Reference Rate Working Group

1. K
    ey Timelines and Milestones for the transition from IBORs to RFRs;

2. S
    napshot of the IBOR and RFR variables associated with each
   currency;

3. ‘At a Glance’ Tracker of each official sector working group activities
   and near-term expected actions.

*Current as of September 2019

                                                                                                                                                             1
IBORs to RFRs Transition Timeline
This timeline lists key dates and milestones associated with the transition from IBORs to risk free rates for the
Japanese yen, Euro, UK pound sterling, U.S. dollar, Swiss franc, Australian dollar, Canadian dollar, Hong Kong
dollar and Singapore dollar.

                                                                                    ECB publishes
                                                                                    summary of responses
                                                                                    for the third public        BoJ publishes public
                                                                                                                                                                                 Legend
                                                                                                                                                 Bank of Canada
        Recommends                                                                  consultation by the         consultation on the              to become                           JAPAN
        TONAR be                                                                    working group on            appropriate choice and           administrator
                                          EMMI announces end                        Euro risk-free rates on     usage of Japanese Yen
        calculated by                                                                                                                            of CORRA                            E
                                                                                                                                                                                     U
                                          to efforts on EONIA                       the EONIA to ESTR           Interest rate benchmarks
        BOJ
                                          reform. Selects €STR as                   legal action plan
                                          replacement for EONIA                                                 EMMI receives license for
                                                                                                                                                                                     UK
                                                                                                                                                            CARR plans
                   Some                                                        EMMI concludes                   the administration of Euribor               to implement             Australia
   Cash Rate       EURIBOR                                                     recalibration                    from the Belgian FSMA                       enhanced
                                                  WG publishes                 of EONIA                                                                     methodology
   methodology     tenors cease                                                                                                                                                      US
                                                  responses to Term                                             WG Euro RFR                                 for CORRA
   introduced      to exist                                                    methodology as
                                                  Sonia Reference Rates                                         Publishes                  ECB
                                                                               €STR + 8.5bp as                                                                                       Switzerland
                                                  (TSRR) consultation                                           Recommendations            publishes
                                                                               of October 2019
                                                                                                                on the Legal Action        €STR
                                                         WG publishes “Next                                     Plan for Transition                             Conversion           Canada
                                                         Steps” paper on                                        from EONIA to €STR                              mechanisms
                                                                                                                                                                consulted            HK
                                                         development of
                                                                                                                       Expects discussion                       on and
                                                         TSRR and issuance                Releases roadmap                                                                           SG
                                                                                                                       paper on legacy                          developed
                                                         of first SONIA-linked            by Working Group             cash products                            for GBP
                                                         securitisation [retained         and findings of the                                                                        O
                                                                                                                                                                                      ther regulatory
                                                                                                                       referencing GBP                          LIBOR to
                                                         on balance sheet]                “Dear CEO” letters                                                                         milestones
                                                                                                                       LIBOR                                    SONIA
       May   Dec        Sept                  Sept   Nov    Dec                               May June          July       Q4          Oct             Q1     Q2
2016 2016 2016 2017 2017          2018        2018   2018   2018   2019                       2019 2019         2019      2019         2019    2020 2020 2020          2021               2022

                         Oct Dec Apr July         Oct                  Mar      Q2         April                    Aug                            Early      July Oct Q1     Q4 End of       Start of
                         2017 2017 2018 2018      2018                 2019    2019        2019                     2019                           2020       2020 2020 2021 2021 2021         2022

                                  Fed                                      Final recommendations                                                   CME plans                  Expect
                                  publishes                                for fallback contract                                                   discounting                term
                                  SOFR                                     language for FRNs,                                                      switch from daily          publication
                                                                           bilateral business                                                      effective federal          of SOFR     Transitional
                                                                           loans, syndicated loans                                                 funds rate                             provisions of
                          ABS-SFEMC
                                                                           and securitizations                                                     (EFFR) to SOFR                         the Benchmark
                          issues                                                                              MAS establishes
                          consultation                                                                        steerco to                                                                  Regulation
                                                                                                                                                       LCH plans                          expire. BMR
                          on enhancing            Recommends                    ARRC releases a               facilitate SOR                           discounting                        comes into force
               Recommends SIBOR                   compounded                    user guide for SOFR           transition to SORA                       switch to SOFR
               SARON                              SARON as term                 encouraging transition                                                                                    EONIA new
                                                  reference rate                                              ABS-SFEMC issues
                                                                                WGARR releases                                                                                FCA no      business after
                         ABS-SFEMC develops                                                                   consultation on                  Enhanced
                                                                                consultation on                                                                               longer      this date must
                         proposal to strengthen                                                               SORA transition                  SIBOR to be
                                                                                refinements for                                                                               compels     reference €STR
                         SIBOR based on                                                                       from SOR                         implemented
                                                                                HONIA as ARR                                                                                  panel
                         consultation responses                                                                                                                                           Basel III
                                                                                                                                                                              banks to
                                                             BIS releases a                        FSB publishes       Expected                  Data collection begins on    submit      and FRTB
                                                             primer on the new                     user guide for      finalized ISDA            model-ability criteria for   LIBOR       implementation
                                                             benchmark rates                       overnight RFRs      fallback language         FRTB implementation          quotes      goes live

                                                                                                                                                                                                           2
Snapshot: Variables of each IBOR and RFR by Jurisdiction
The following lists out the key factors to be aware of in each IBOR and risk-free reference rate.

                                                       Reformed
                                                       IBOR include Alternative        Alternative RFR Transaction Overnight   Secured/    Underlying   Rates
 Jurisdiction   Benchmark IR       Administrator
                                                       waterfall    RFR                Administrator   based?      rate?       Unsecured   Transactions Published
                                                       approach?

                  JBA TIBOR
                                      JBA TIBOR
                   EUROYEN                                  Yes                                           Yes
                                     Administration
                    TIBOR
                                                                                                                                             Money
                                                                           TONA        Bank of Japan                  Yes      Unsecured                   July 1985
                                                                                                                                             Markets
    Japan                           ICE Benchmark
                  JPY LIBOR          Administration         Yes                                           Yes
                                         (IBA)

                                                                        Euro short-
                                                                         term rate                        Yes                                              October
                    EONIA/         European Money                         (€STR)         European
                                                                                                                      Yes                    Money          2019
                   EURIBOR         Markets Institute        Yes                         Central Bank                           Unsecured
                                                                                                                    (€STR)                   Markets       (€STR)
                                       (EMMI)                                              (ECB)
     EU                                                                  Reformed
                                                                                                         Partly
                                                                         EURIBOR

                                                                         Reformed
                                                                          sterling
                                    ICE Benchmark
                                                                         overnight        Bank of                                            Money          23 April
                  GBP LIBOR          Administration         Yes                                           Yes         Yes      Unsecured
                                                                           index          England                                            Markets         2018
                                         (IBA)
     UK                                                                   average
                                                                         (SONIA)

                                                                          Secured          Federal
                                    ICE Benchmark
                                                                        overnight       Reserve Bank                                          Repo
                  USD LIBOR          Administration         Yes                                           Yes         Yes       Secured                   3 April 2018
                                                                         financing      of New York                                        Transactions
                                         (IBA)
      US                                                               rate (SOFR)        (FRBNY)

                                                                          Swiss
                                    ICE Benchmark
                                                                       average rate      SIX Swiss                                            Repo        25 August
                  CHF LIBOR          Administration         Yes                                           Yes         Yes       Secured
                                                                        overnight        Exchange                                          Transactions     2009
                                         (IBA)
                                                                        (SARON)
 Switzerland

                                                                                                                                                                       3
Snapshot: Variables of each IBOR and RFR by Jurisdiction
The following lists out the key factors to be aware of in each IBOR and risk-free reference rate.

                                                       Reformed
                                                       IBOR include Alternative        Alternative RFR Transaction Overnight   Secured/    Underlying   Rates
 Jurisdiction   Benchmark IR       Administrator
                                                       waterfall    RFR                Administrator   based?      rate?       Unsecured   Transactions Published
                                                       approach?

                                       Australian                        RBA Cash       Reserve Bank                                                      Current
                Bank Bill Swap                                                                                                             Cash Market Methodology
                                       Securities           Yes            Rate          of Australia     Yes         Yes      Unsecured
                Rate (BBSW)                                                                                                                Transactions Introduced
                                    Exchange (ASX)                       (AONIA)            (RBA)                                                        May 2016
  Australia

                                       Thomson                                             Refinitiv                                                      Enhanced
                                       Reuters –                                         transferring                                                      CORRA
                                                                                                                                              Repo
                     CDOR              Refinitiv            No            CORRA           to Bank of      Yes         Yes       Secured                     to be
                                                                                                                                           Transactions
                                      Benchmark                                           Canada in                                                       Published
   Canada                              Services                                              2020                                                         Q2 2020

                                                                                                                                            Overnight
                                                                                         Hong Kong                                          Interbank
                                      Hong Kong                                                                                                           Enhanced
                                                                                          Treasury                                            Deals
                                   Treasury Markets                                                                                                        HONIA
                     HIBOR                                  No            HONIA           Markets         Yes         Yes      Unsecured     Routed
                                      Association                                                                                                         yet to be
                                                                                         Association                                         Through
                                        (TMA)                                                                                                             published
 Hong Kong                                                                                 (TMA)                                              Money
                                                                                                                                             Brokers

                                   The Association
                                                                          None
                     SIBOR            of Banks in           Yes
                                                                         Selected
                                   Singapore (ABS)

                                                                                                                                            Unsecured
                                                                                                                                             overnight
                                                                                         Monetary                                                         Published
                                   The Association                        SORA                                                               interbank
 Singapore                                                                              Authority of                                                       daily by
                      SOR             of Banks in                        pending                          Yes         Yes      Unsecured        SGD
                                                                                         Singapore                                                        MAS since
                                   Singapore (ABS)                     consultation                                                        transactions
                                                                                           (MAS)                                                          July 2005
                                                                                                                                            brokered in
                                                                                                                                            Singapore

                                                                                                                                                                      4
At a Glance: Official Sector Working Group
Activities and Near-Term Expectations
This tracker follows the official sector working group activities, near-term expected actions, industry
actions around cash fallback language, term rate statuses, and issuance of alternate RFRs to date.

Working                  Working Group                  Alternative/New             Cash Fallback             Term Rate                 Near Term Expected
                                                                                                                                                           Issuance to Date
Group                    Structure                      RFR Status                  Language Status           Status                    Actions

                         The Cross-Industry             December 2016:                                        Future work plan for      The Committee released
                         Committee on Yen Interest      Recommended Tokyo                                     term reference rate       a Public Consultation
                         Rate Benchmarks is divided     Overnight Average Rate                                based on Swaps and        on the Appropriate
                         into three subgroups and       (TONA) calculated by the                              Futures is discussed in   Choice and Usage of
                         one working group              Bank of Japan.                                        the subgroup for the      Japanese Yen Interest
 Bank of Japan Study     focusing on:                                                                         development of term       Rate Benchmarks on 2
 Group on Risk-Free                                                                                           reference rates. The      July 2019
 Reference Rates         1. Loans
                                                                                                              subgroup considers
 Cross-Industry          2. Bonds                                                                            possible timing of the
 Committee on                                                                                                 implementation is
                         3. Development of term
 Japanese Yen Interest                                                                                        around mid-2021.
                            reference rates
 Rate Benchmarks
                         4. Currency Swaps

                         The Euro Working Group         September 2018:             Euro WG “Guiding          On 25 Feb, the WG                                  There is no issuance in
                         (WG) currently has five        Recommended €STR to         principles for fallback   published a summary                                €STR yet.
                         sub-groups, focusing on:       replace EONIA.              provisions in new         of responses to
                                                                                    contracts for euro-       the second public
                         1. Term rate methodology      ECB will begin publishing
                                                                                    denominated cash          consultation on
 Working Group on           for euro short-term rate    €STR by October 2, 2019.
                                                                                    products” published       determining an €STR-
 Euro Risk-Free Rates    2. Best practices for         February 2019:              in 2019 to promote        based term structure
                            contract robustness and     Euro WG confirms            effective fallback        methodology as
                            legacy contracts            EURIBOR will continue for   provisions in new         a fallback in euro
                                                        the medium term.            contracts for euro-       interbank offered rate
                         3. Identification and
                                                                                    denominated cash          (EURIBOR) linked
                            adoption of RFRs for cash
                                                                                    products.                 contracts.
                            products and derivatives
                                                                                    In 2019, the WG           The ECB has
                         4. Risk management and
                                                                                    intends to recommend      announced a call
                            accounting issues
                                                                                    more detailed fallback    to benchmark
                         5. Communication and                                      language. Much of this    administrators for
                            education with market                                   is outlined in the WG     expressions of interest
                            participants                                            Legal Action Plan.        in administering
                                                                                                              an €STR-based
                                                                                                              forward-looking term
                                                                                                              structure.
                                                                                                              The WG may seek
                                                                                                              further input from
                                                                                                              market participants
                                                                                                              through additional
                                                                                                              consultations.

                                                                                                                                                                                           5
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued)

Working                 Working Group                  Alternative/New              Cash Fallback             Term Rate                Near Term Expected
                                                                                                                                                          Issuance to Date
Group                   Structure                      RFR Status                   Language Status           Status                   Actions

                        The WG is broken down into     April 2017:                  GBP fallback language     The RFRWG                A 2019 focus will be         To date there have been 68
                        sub-groups focusing on:        Recommended reformed         expected to be            have confirmed           on development of            issues of sterling floating
                                                       Sterling Overnight Index     agreed in 2019.           FTSE Russell,            operational capability       rate notes which reference
                        1. Bonds
                                                       Average (SONIA).                                       ICE Benchmark            for SONIA-referencing        SONIA with total volume of
Bank of England         2. Loans                                                                             Administration,          floating rate notes          £33.6 bn, this is in addition
Working Group on                                                                                              Refinitiv and HIS        (FRNs), loans and other      to 18 sterling securitisation
                        3. Communications
Sterling Risk-Free                                                                                            Markit are working       instruments. A term          deals referencing SONIA
                           & Outreach
Rates (RFRWG)                                                                                                 on development           benchmark rate will be       with total volume of £16.7bn.
                        4. Pension Funds &                                                                   of a Term SONIA          produced and made            There has also been 1
                           Insurance Companies                                                                Reference Rate.          available to use.            corporate loan to National
                                                                                                                                                                    Express which references
                        5. Infrastructure                                                                                             The RFRWG maintains
                                                                                                                                                                    SONIA.
                                                                                                                                       “Working Group Timeline
                        6. Term Rates (Task Force)
                                                                                                                                       and Milestones.”
                        7. Accounting/Tax (Task
                            Force)
                        8. R
                            egulatory Dependencies
                           (Task Force)

                        The WG is broken down into     June 2017: Recommended       ARRC agreed on            ARRC’s Paced             ARRC to publish              CME Group launched
                        sub-groups focusing on:        Secured Overnight            principles for fallback   Transition Plan sets     recommended fallback         3-month and 1-month SOFR
                                                       Financing Rate (SOFR)        language, published       end of 2019 goal to      language for adjustable      futures trading on 7 May
                        1. Accounting/Tax
                                                       as the RFR to replace U.S.   late Sept 2018.           produce a forward-       rate mortgages after         2018. LCH began clearing
Alternative Reference   2. Business Loans             dollar LIBOR.                                          looking term rate for    the completion of their      SOFR swaps in July 2018.
                                                                                    In Q2 2019, the
Rates Committee                                                                                               use in certain cash      consultation.
                        3. Consumer Products           April 2018: New York         ARRC released                                                                   SOFR-based bond
(ARRC)                                                                                                        products.
                                                       Federal Reserve              recommended                                        The ARRC will continue       issuances in recent months
                        4. Floating Rate Notes
                                                       Bank (NYFRB) began           fallback contract         The FRB published        to pursue regulatory         include Fannie Mae, Credit
                        5. Legal                      publication of SOFR.         language for bilateral    various sets of data     and other obstacles to       Suisse, Wells Fargo, Met
                                                                                    business loans,           on indicative forward-   a transition away from       Life, the Federal Home Loan
                        6. Market Structure and
                                                                                    floating rate notes,      looking SOFR term        SOFR. It is also exploring   Bank system and the World
                           Paced Transition
                                                                                    securitizations and       rate data (last update   educational and outreach     Bank. There have been 289
                        7. Operations/Infrastructure                                syndicated loans.         April 2019)              objectives and plans.        issues of U.S. dollar notes
                        8. Outreach/                                                                                                                               referencing SOFR with total
                                                                                    In July 2019, ARRC
                           Communications                                                                                                                           volume of $292bn
                                                                                    opened a consultation
                        9. Regulatory Issues                                       for fallback contract
                                                                                    language for
                        10. Securitizations                                        adjustable rate
                        11. Term Rates                                              mortgages.

                        The WG is broken down into     October 2017:                                          WG has                                                On 29/10/2018 Eurex
                        sub-groups focusing on:        Recommended Swiss                                      recommended using                                     launched 3M SARON
                                                       Overnight Average Rate                                 compounded SARON                                      Futures
                        1. Derivatives & Capital
                                                       (SARON).                                               wherever possible
                           Markets
National Working        2. Loan and Deposit Markets
Group on Swiss Franc
Reference Rates

                                                                                                                                                                                                    6
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued)

Working                Working Group                   Alternative/New              Cash Fallback        Term Rate               Near Term Expected
                                                                                                                                                    Issuance to Date
Group                  Structure                       RFR Status                   Language Status      Status                  Actions

                       RBA recognizes three            BBSW has been                                     BBSW has been           RBA and relevant            The current calculation
                       working groups related to       strengthened and will                             strengthened and        regulators will continue    methodology for AONIA was
                       interest rate benchmark         continue to be published                          will continue to be     to monitor both BBSW        introduced in May 2016.
                       reform.                         going forward.                                    published.              and AONIA.
                                                                                                                                                             South Australian
Reserve Bank of
                       1. ASX BBSW Advisory           AONIA is being published                          RBA evaluated that                                  Government Financing
Australia Interest
                          Committee focuses on         as an RFR in as part of a                         there are enough                                    Authority (SAFA) launched
Rate Benchmark
                          BBSW Benchmark               “multiple rates” approach.                        transactions to                                     an AONIA linked AUD
Reform Page
                                                                                                         determine BBSW and                                  floating rate note. The
                       2. Australian Financial
                                                                                                         that it will continue                               issue amount was A$500
                          Markets Association
                                                                                                         to exist as part of a                               million and it was launched
                          (AFMA) focuses on
                                                                                                         multi-rates approach.                               with UBS as the Arranger
                          promoting industry
                                                                                                                                                             and Sole Lead Manager,
                          dialogue and information
                                                                                                                                                             and IHS Markit as the
                          sharing
                                                                                                                                                             calculation agent.
                       3. Australian Securitisation
                          Forum (ASF) established
                          a working group to
                          consider benchmark
                          reform on the Australian
                          Securitisation Market

                       The Canadian Alternative        CARR endorses an             CARR developed       CDOR will continue      Fallback language will      CORRA exists in the market,
                       Reference Rate Working          enhanced CORRA based         Principles for       to exist as a part      be finalized after ISDA     but enhanced CORRA is still
                       Group (CARR) is sponsored       on the recommendations       Enhancements to      of a multiple rates     finishes its consultation   under development and has
                       by the Canadian Fixed-          outlined in their            Fallback Language.   approach.               on fallback language for    not yet been published.
                       Income Forum (CFIF)             consultation paper with                                                   CDOR and other rates.
Canadian Alternative   which is a group set up by      no changes based on
Reference Rate                                                                                                                   CARR and CFIF will
                       the Bank of Canada. Both        responses.
Working Group                                                                                                                    monitor and review issues
                       groups are comprised
                                                       CFIF endorses                                                             for transition from CORRA
                       of market participants
                                                       monitoring and reviewing                                                  to an enhanced CORRA.
                       and Bank of Canada
                                                       issues for transition by
                       representatives.                                                                                          Bank of Canada to
                                                       the transition subgroup
                                                                                                                                 become CORRA
                                                       and by the benchmark
                                                                                                                                 administrator in 2020.
                                                       admin.

                                                                                                                                                                                           7
At a Glance: Official Sector Working Group Activities and Near-Term Expectations (continued)

Working                 Working Group                 Alternative/New             Cash Fallback     Term Rate                 Near Term Expected
                                                                                                                                                 Issuance to Date
Group                   Structure                     RFR Status                  Language Status   Status                    Actions

                        As HONIA’s administrator,     The WGARR has                                 HIBOR will continue       Technical adjustments          HONIA exists in the market,
                        the TMA established an        proposed technical                            to exist as a part        may be made to HONIA           but the updated HONIA has
                        internal Working Group on     refinements to HONIA                          of a multiple rates       based upon industry            not yet been developed.
                        Alternative Reference Rates   outlined in an April 2019                     approach.                 feedback to the
                        (WGARR).                      consultation paper.                                                     consultation paper.
                                                                                                    TMA may also try to
Hong Kong Treasury
                                                      Refinements relate to                         develop an OIS curve      There are no plans to
Markets Association
                                                      the rate’s data source,                       for HONIA depending       discontinue HIBOR and a
Working Group on
                                                      reporting window and                          on market conditions      multi rate approach will
Alternative Reference
                                                      publication time.                             and demand.               be adopted using both
Rates “WGARR”
                                                                                                                              HONIA and HIBOR.
                                                      The TMA and WGARR
                                                      plan to issue a paper                                                   Fallback language will
                                                      based on feedback                                                       be developed after ISDA
                                                      received by industry                                                    finishes its consultation
                                                      stakeholders.                                                           on fallback language for
                                                                                                                              HIBOR and other rates.

                        MAS has established a         The ABS Benchmarks Co                         SIBOR will continue to    Enhanced SIBOR will            SORA is currently under
                        Steering Committee for        Pte td and the Singapore                      be published.             go through testing and         consultation to replace SOR.
                        SOR Transition to SORA        Foreign Exchange Market                                                 transition late 2019 – early   SORA has been published
                                                                                                    An enhanced SIBOR
                        (SC-STS).                     Committee (ABS-SFEMC)                                                   2020.                          since July 2005.
                                                                                                    will be implemented in
                                                      have worked together to
                                                                                                    late 2019 – early 2020.   ISDA released a
Steering Committee                                    develop a proposal to
                                                                                                                              consultation for fallback
for SOR Transition to                                 strengthen SIBOR. ABS-
                                                                                                                              language suggesting that
SORA (SC-STS)                                         SFEMC also released
                                                                                                                              SOR reference SOFR as
                                                      a consultation on the
                                                                                                                              a fallback rate. Fallback
                                                      proposed transition from
                                                                                                                              language may be adopted
                                                      SOR to SORA.
                                                                                                                              for SOR to reference
                                                                                                                              SOFR in place of USD
                                                                                                                              LIBOR for derivative
                                                                                                                              contracts.
                                                                                                                              ABS-SFEMC released
                                                                                                                              a consultation on the
                                                                                                                              roadmap for transition
                                                                                                                              from SOR to SORA in
                                                                                                                              August 2019.

                                                                                                                                                                                            8
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