NYDFS Requires Covid-19 Preparedness Plans From Regulated Entities

The arrival of Novel Coronavirus ("COVID-19") in New York, and the United States more generally, has roiled the U.S. and global economy and significantly affected numerous businesses. In light of these circumstances, the New York Department of Financial Services ("NYDFS") released a set of industry letters on March 10, 2020 (the "Industry Letters") that: (i) require regulated institutions to have preparedness plans in place to address operational and financial risks posed by the outbreak of COVID-19 and to submit a description of those plans to the NYDFS, and (ii) encourage New York regulated banks, credit unions and licensed lenders to consider all reasonable and prudent steps to assist businesses that have been adversely impacted by COVID-19. On March 12, 2020, the NYDFS also provided relief by order of the Superintendent of the NYDFS from certain New York Banking Law notice requirements (including with respect to office closures or relocations), as well as