On 6 February 2020, the International Swaps and Derivatives Association (ISDA) published an updated version of its FAQs on IBOR Fallback Rate Adjustments.

The FAQs insert a new question and answer on whether fallbacks are “benchmarks” for regulatory purposes. ISDA responds to this question by stating:

• It is important to keep in mind that the IBOR transition is to risk free rates (RFRs) produced by central banks based upon robust transaction data. The RFRs remain the essential benchmarks and the ISDA does not view the adjustments as changing that. Rather, the adjustments facilitate the adoption of these RFRs by applying straightforward calculations according to publicly available, transparent rules.
• However, given the nature of this activity, Bloomberg is conducting the calculation of the adjustments within Bloomberg Index Services Limited, its authorized benchmark administrator.

In addition to the updated FAQs, ISDA has published a table laying out work streams related to the transition from IBORs and other interest rate benchmarks and the development of alternative RFRs.