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Bob Zwirb Commentary by Bob Zwirb

As a part of its comprehensive review of swap data reporting regulations, the CFTC approved a proposal intended to improve "the quality of swap data" and the swap data repository operations and governance.

The Alternative Reference Rates Committee ("ARRC") provided recommended contractual fallback language for U.S. dollar LIBOR-denominated floating rate notes and syndicated loans. The recommendation, according to the ARRC, addresses risks in contracts that reference LIBOR and builds on the " Paced Transition Plan," which sets forth steps for an efficient shift to the Secured Overnight Financing Rate ("SOFR"). The ARRC's recommended fallback language for floating rate notes "defines the trigger events that start the transition away from LIBOR" and lays out a "waterfall" approach to determine the