New York DFS Requires Submission of LIBOR Cessation and Transition Risk Management Plans by March 23, 2020

On December 23, 2019, the New York Department of Financial Services (DFS) announced that it is requiring New York-regulated depository and non-depository institutions, insurers and pension funds (NY Regulated Entities) to submit their plans for managing the risks relating to the likely discontinuation of the London Interbank Offered Rate (LIBOR) at the end of 2021.

In a related letter sent to all NY Regulated Entities, DFS designated February 7, 2020, as the deadline for submitting these plans. In a later letter, dated January 23, 2020, DFS announced that the deadline has been extended to March 23, 2020, the "final deadline."