The New York State Department of Financial Services ("NYDFS") extended the deadline for regulated entities to submit their plans for handling the end of LIBOR and the associated risks. The deadline was extended from February 7, 2020 to March 23, 2020.
The NYDFS granted this extension in response to "numerous requests." However, NYDFS Superintendent Linda Lacewell warned that this is a final deadline. As previously covered, the NYDFS issued an Industry Letter asking institutions to describe:
- programs that would assess the financial and nonfinancial transition risks;
- how alternative rates will be monitored and assessed for their impact on customers, counterparties and the institutions themselves;
- processes to communicate with customers and counterparties;
- a plan for "operational readiness" (i.e., account, tax and reporting practices); and
- their governing oversight framework.
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