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On Oct. 22, 2020, the Alternative Reference Rates Committee (“ARRC”) released an update to an announcement formerly released on Oct. 9, 2020 encouraging market participants to adhere to the upcoming IBOR Fallbacks Protocol to be published by the International Swaps and Derivatives Association Inc. (“ISDA”). The ARRC updated the announcement to add reference to an Oct.21, 2020 letter from the Federal Housing Financing Agency (“FHFA”) to Federal Home Loan Bank Precedents on ISDA’s protocol, advocating signing the protocol by the close of the escrow period (Oct. 23, 2020), or else by no later than Dec. 21, 2020.

Key Publications

The ARRC Announcement

The FHFA Letter