On March 12, 2020 NYDFS issued an “Order Granting Temporary Relief to COVID-19 Affected Regulated Entities and Persons.” This rather extraordinary order specifically acknowledges that “COVID-19 may present compliance challenges” and includes several significant provisions for regulated entities adversely impacted:

● Extends by 45 days the date by which regulated entities or persons must file certifications of compliance with the Cybersecurity Regulations (Part 500) and Transaction Monitoring/Filtering Regulations (Part 504).

● Extends by 45 days the date by which virtual currency licensees must file a Quarterly Financial Statement;

● Facilitates remote workforce activity by specifically acknowledging that individuals conducting “licensable activities from their personal residences” remain subject to the full supervision of the Department and must ensure compliance with required controls, such as for cybersecurity and data protection; and

● Waives the required advance notice where a regulated entity seeks to temporarily relocate an authorized place of business or close a branch office.

The emergency Order may be found here:  https://www.dfs.ny.gov/system/files/documents/2020/03/ea20200312_covid19_relief_order.pdf