Company X has issued fixed-rate debt and wishes to "unlock" its interest rate exposure as it believes variable rates may decline. The company enters into an interest rate swap whereby it agrees to receive a fixed rate of interest, and pay a variable rate referenced to LIBOR and based on a notional amount that corresponds to the principal amount of the debt. Which of the following is false?

a.the company may be impacted by reference rate reform and therefore should consider the implications of ASC 848

b. the transaction the company is contemplating may qualify as a fair value hedge

c. in order to achieve hedge accounting, the company will need to address a number of hedge accounting requirements, including documenting its objectives, the method of testing effectiveness among other matters

d. interest rate risk is not an eligible risk for hedge accounting purposes since it is clearly and closely related to the economic characteristics of debt