NYDFS Extends Deadline For "Comprehensive" And "Robust" LIBOR Transition Plans To March 23

On January 23, New York State Department of Financial Services (DFS) Superintendent Linda Lacewell announced in a brief statement ¹ and letter ² that the DFS extended the deadline for LIBOR transition plans by 45 days to March 23, 2020. Superintendent Lacewell stated that the DFS expects institutions to submit "complete and comprehensive plans" by the new, "final deadline." In the letter, Superintendent Lacewell stated that "[i]t is imperative that regulated institutions with LIBOR exposure have robust and comprehensive plans in place to address their risk."

As we discussed in our previous Advisory, in late December the DFS issued an industry letter directing DFS-regulated institutions to submit responses describing each institution's plans to address its LIBOR cessation and transition risk, detailing aspects from operational readiness to consumer and counterparty communication to corporate governance. The DFS's call for written plans accelerates financial