Financial institutions around the world are addressing the probable cessation of "LIBOR" interest rates before 2022 by, among other things, developing language designed to substitute an industry-approved successor rate (most likely to be based on the "Secured Overnight Financing Rate," or "SOFR," for the U.S. dollar) seamlessly in the event of such a cessation. The Alternative Reference Rates Committee ("ARRC") has recently released its final "fallback language" recommendations for USD-denominated securitizations ("Securitizations") and bilateral business loans ("Bilateral Loans"). While the recommended language is "final," it leans heavily on future market developments to provide fundamental calculation conventions. We would expect to see the recommendations for Bilateral Loans to be implemented relatively quickly for new and amended loans, but it remains to be seen to what extent the "Hedged Loan Approach" will be adopted in the market. The recommended language for Securitizations has already been implemented in a Ford auto loan securitization.