On October 7, 2019, ISDA’s responded to the Financial Accounting Standards Board’s (FASB) exposure draft file reference number 2019-770 on reference rate reform (Topic 848). ISDA members support the FASB’s proposals in the exposure draft to provide optional expedients and exceptions to applying US GAAP to derivatives and hedging relationships and other transactions and contracts that will be affected by reference rate reform. ISDA is in favor of the exposure draft’s targeted improvements, but, at the same time, is requesting additional clarification to avoid unintended consequences.