It is widely anticipated that the London Interbank Offered Rate (“LIBOR”) will be discontinued in 2021. As LIBOR commonly is used as an index rate for both residential mortgage and consumer loans, its discontinuance has the potential to have a significant impact on lenders, servicers, and consumers. Since 2014, industry leaders have been working to settle on an alternative index and transition plan to minimize the disruption of the move away from LIBOR. Through its efforts, the Alternative Reference Rates Committee (“ARRC”)1 has identified a newly created rate, the Secured Overnight Financing Rate (“SOFR”), as a suitable LIBOR replacement and has established a SOFR implementation framework.