On November 13, ISDA responded to the Financial Accounting Standards Board’s (FASB) Reference No. 2020-900 Reference Rate Reform (Topic 848) public consultation. ISDA’s members support the FASB’s proposals to address the accounting implications of the discounting transition for derivatives contracts that do not reference a rate that is expected to be discontinued. In the response, ISDA’s members include additional feedback and proposed refinements for the FASB’s consideration.