January 13, 2020
At the end of December, the New York Department of Financial Services (the NYDFS) published an industry letter to regulated institutions regarding LIBOR cessation. The NYDFS is requiring that each “regulated institution” submit a response to the NYDFS by February 7, 2020, describing the institution’s plan to address its LIBOR cessation and transition risk.
Among the kinds of transactions identified by the NYDFS are LIBOR-linked credit transactions (including business loans, floating rate notes and bonds, consumer loans and residential mortgages); derivatives (including interest rate swaps); and securities transactions (including securitizations). The NYDFS has also highlighted asset- and liability-side exposure to LIBOR.
Specifically, the plan should describe:
Among the institutions covered by the requirements are depository institutions (banks), non-depository institutions (licensed lenders, money transmitters and virtual currency companies) and insurance companies.
On January 23, 2020, the Department announced that the deadline for submissions would be extended for 45 days from February 7 to March 23, 2020.