We strongly support the Board’s proposed rule, particularly the determination that no conforming changes are needed for consumer loans. But we recommend two clarifications for non-covered consumer contracts: a) declare that the Board-selected benchmark replacement for non-covered consumer contracts is the same as the replacement selected for covered consumer contracts; and b) adopt a rule clarifying that any fallback language dependent on the “availability” of the LIBOR shall be triggered on the earlier of the date specified in the contract (if any) or the LIBOR replacement date.
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