On May 20, ISDA responded to the European Financial Reporting Advisory Group’s (EFRAG) Pre-Consultation on Interest Rate Benchmark Reform – Phase 2 – Exposure Draft: ED/2020/1. ISDA supports the EFRAG’s efforts to provide input to the International Accounting Standards Board to amend international financial reporting standards in response to interbank offered rate reform, and agrees with the technical expert group views proposed in the consultation. The amendments are necessary to facilitate an orderly transition to risk-free rates.