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ISDA published the ISDA 2018 Benchmarks Supplement Protocol (the "Protocol"), which provides market participants with a multilateral method for applying the terms of the ISDA Benchmarks Supplement (the "Benchmarks Supplement") to certain derivatives transactions, including certain interest rate, foreign exchange, equity and commodity derivatives transactions. The Protocol permits adherents to the Protocol ("Protocol Participants") to incorporate the terms of the Benchmarks Supplement to transactions entered into either with all other counterparties that are Protocol Participants or on a

ISDA summarized preliminary responses to a July 2018 consultation related to new benchmark fallbacks for derivative contracts that cite various interbank offered rates ("IBORs"). As previously covered , the consultation set forth alternatives for adjusted risk-free rates ("RFRs") and spread adjustments that would apply in the event an IBOR is permanently discontinued. ISDA received 152 responses to the consultation, representing a wide cross-section of market participants. According to ISDA: the "overwhelming majority" of respondents preferred the "compounded setting in arrears rate" for the