On the heels of SEC Chair Clayton's and Staff's repeated cautionary remarks concerning the need for companies to evaluate and disclose material LIBOR phase-out-related risks (see most recently here & here), Cooley's timely "LIBOR phase-out—issues to consider" discusses how the proposed alternative reference rate - Secured Overnight Financing Rate, or “SOFR" - differs from LIBOR, and some of the potential practical implications of the phase-out that should help inform companies' further diligence, financial disclosure, and other responsive actions.