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ARTICLE · 28 MARCH 2020

NYDFS Adopts Forbearance Regulations For Regulated Institutions

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The New York Department of Financial Services ("NYDFS") promulgated regulations ("Part 119") on March 24, 2020, to provide financial relief to individuals who can demonstrate a financial hardship...

United StatesFinance and Banking
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The New York Department of Financial Services ("NYDFS") promulgated regulations ("Part 119") on March 24, 2020, to provide financial relief to individuals who can demonstrate a financial hardship as a result of the COVID-19 pandemic (the "Mortgage Forbearance Regulation"). The regulation establishes the scope of requests that regulated institutions must consider, and standards and procedures that regulated institutions must follow in their review of requests for relief.

On March 21, 2020, Governor Cuomo signed an Executive Order, No. 202.9, Continuing Temporary Suspension and Modification of Laws Relating to Disaster Emergency (the "Executive Order") which modifies Section 39(2) of the New York Banking Law to provide that it is an unsafe and unsound business practice for any bank subject to the NYDFS to not grant a forbearance to any person or business who has a financial hardship as a result of the COVID-19 pandemic for 90 days. The Mortgage Forbearance Regulation

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