On June 25, 2020, the Federal Reserve, Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Office of the Comptroller of the Currency (the “Agencies”) finalized amendments to...more
COVID-19 has acted as an accelerator, bringing into play scenarios which were previously only contingencies and making contingencies of (and requiring planning for) situations which were previously barely imaginable. The debt...more
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”...more