by Mylan L. Denerstein, Matthew L. Biben, James L. Hallowell, Mitchell A. Karlan, Arthur S. Long, and Emil N. Nachman

On March 21, 2020, New York Governor Andrew Cuomo issued an Executive Order relating to  90-day forbearances for borrowers that are suffering financial hardship as a result of the COVID-19 pandemic.  In part, this Executive Order called on the New York Department of Financial Services (DFS) to promulgate emergency regulations in furtherance of the Governor’s directive.  On March 24, 2020, the New York Superintendent of Financial Services, Linda A. Lacewell, promulgated regulations implementing the Executive Order (Emergency Regulations).  Importantly, the Emergency Regulations clarify ambiguities in the Executive Order and demonstrate a focus on consumer and individual forbearances. Continue reading →