The New York State Department of Financial Services ("NYDFS") instructed its regulated entities to outline their plans to address the end of LIBOR and the associated risks.

In an Industry Letter, the NYDFS asked institutions to describe:

  • programs that would assess the financial and non-financial transition risks;

  • how alternative rates will be monitored and assessed for their impact on customers, counterparties and the institution itself;

  • processes to communicate with customers and counterparties;

  • a plan for "operational readiness" (i.e., account, tax and reporting practices); and

  • their governing oversight framework.

Responses must be submitted to the NYDFS by February 7, 2020.

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