NYDFS Guidance in Response to COVID-19: NYDFS Issues Order Granting Temporary Relief from Requirements of Certain New York State Banking and Finance Laws to Affected DFS Regulated Entities

Sullivan & Cromwell LLP - March 19, 2020

On March 12, 2020, the Superintendent of the New York State Department of Financial Services issued an order granting temporary relief from certain requirements of the New York Banking Laws and the New York Financial Services Laws and the regulations promulgated thereunder to regulated entities affected by COVID-19. The Superintendent explained that the DFS was issuing the Order to help regulated entities meet their ongoing compliance obligations under the New York Banking and Financial Services Laws while managing disruptions associated with the COVID-19 outbreak. Key forms of relief include the modification of the DFS’s application requirements to close or relocate an authorized place of business, branch, office or location and a 45-day extension for certain compliance and reporting filings, including the certification of compliance with the DFS’s Part 504 transaction monitoring and filtering program requirements and the DFS’s cybersecurity program requirements. The Order does not extend the deadlines for notifying the DFS of a cybersecurity event or the submission of a regulated entity’s LIBOR cessation and transition plans.