On June 6, 2022, ISDA submitted a comment letter to the Financial Accounting Standards Board (FASB) in response to its exposure draft (ED). In the letter, ISDA’s members highlighted their support of the proposals to defer the sunset date of topic 848 and clarify the definition of SOFR. ISDA’s members believe the ED achieves the FASB’s objective of easing the burden associated with accounting and disclosing during the transition to interbank offered rates, and identified several areas where the ED’s proposals could be further enhanced.