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Action needed: NY DFS Requires your Response to LIBOR Replacement Memo

January 24, 2020

No need to be alarmed

The initial request gave a 2/7/2020 deadline which they subsequently extended to March 23. 

On Dember 23, 2019 the New York State Department of Financial Services (NYDFS) sent an initial demand letter requiring regulated institutions to provide a copy of their plan for LIBOR transition. Many companies did not respond, so NYDFS sent a subsequent letter extending the deadline to 3/23/2020

The fact that the industry consensus on LIBOR's replacement does not exist yet may make this more difficult. However, thousands of regulated entities - anyone acting in an intermediary role, such as brokering, correspondent lending (not servicing) or institutions that use treasury- or WSJ prime-based indices for contracts and futures - will not have to work to change their structure to replace it. 

Nonetheless, you will have to respond to the request. We've created a template response for you to use and a free assessment tool to gauge whether you will need to adjust your response and business practices

Take LIBOR Assessment Now
Once you have completed your assessment, we will e-mail your results to you. You can copy this email and forward it to the NYDFS at this address: (for mortgage companies, brokers and intermediaries)

Thomas Morgan

1 Research Court, Suite 450
Rockville, MD 20850


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