On May 20, 2016, the New York Federal Reserve Bank’s Alternative Reference Rate Committee released an interim report announcing its preliminary recommendations on a replacement for LIBOR, the interest rate benchmark that dominates the leveraged loan market and has been the subject of ongoing controversy as a result of alleged illegal manipulation in the rate setting process. This alert presents questions for consideration about the interim report, including questions regarding alternative rates, the paced transition from effective federal funds rate to the new rate and the transition from the LIBOR.

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