Manipulation of the LIBOR market during the financial crisis has resulted in billions of dollars in fines and related enforcement actions levied by the global regulatory agencies. As confidence in LIBOR rate setting and governance declined, it was clear a transition to a new benchmarking rate was needed—but the questions of what/how remained. Initial efforts focused on strengthening LIBOR oversight, but during their review global regulators saw that LIBOR was actually supported by far too few actual market transactions and, considering the increased liability banks were now facing, the project’s goal shifted from how to fix LIBOR to finding an alternative reference rate. Since then, central banks around the world have been scrambling to develop alternatives to LIBOR. In June 2017, the U.S. Alternative Reference Rates Committee (ARRC) announced their preferred rate, the Secured Overnight Financing Rate (SOFR). In December 2017, the Fed announced their final plans for the production of three new reference rates with the most comprehensive of the rates, SOFR, to begin in 2Q18. Whether or not market participants choose to use SOFR or some other reference rate is something that will continue to play out in the months and years to come. While the ARRC has proposed a path forward in their Paced Transition Plan—with a total transition to a reference rate based on SOFR set for the end of 2021 (but currently running ahead of schedule)—the transition is still underway and not without risk. As an invited member of the ARRC’s Business Loan Working Group, AFS is keeping abreast of the transition timeline, and has identified four key action items to make sure banks stay on track for the LIBOR transition.