• Comments

Comments to Final LIBOR Rule

Comments submitted in response to the final promulgation of Final Treasury Regulations §1.1001-6 and Final Amendments to §1.1275-2 relating to the transition from interbank offered rates (IBORs) to replacement benchmark rates.

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Commissioner Rettig,

The National Association of Bond Lawyers (“NABL”) appreciates the swift promulgation of Final Treasury Regulations §1.1001-6 and Final Amendments to §1.1275-2 (the “Final Regulations”) relating to the transition from interbank offered rates (IBORs) to replacement benchmark rates. We now wish to provide the attached comments and recommendations to clarify how the Final Regulations are intended to operate in the
context of tax-advantaged bonds.

NABL is a nonprofit organization and specialty bar association of approximately 2,500 lawyers whose purposes include, among other things, providing advice and comment at the federal, state, and local levels with respect to legislation affecting state and municipal
obligations.

Thank you in advance for your time and attention here.

Best,

Joseph (Jodie) E. Smith
President
National Association of Bond Lawyers (NABL)

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