NYDFS Requires COVID-19 Plans by April 9

On March 10, 2020, the New York Department of Financial Services issued guidance to all of its regulated institutions engaged in virtual currency business activity, requiring them to have plans for preparedness to manage the possible operational and financial risks posed by the COVID-19 pandemic. NYDFS requires the plans to be submitted by Thursday, April 9, 2020.

NYDFS does not have a one-size-fits-all set of requirements, but instead requires that the plan be “sufficiently flexible to effectively address a range of possible effects that could result from an outbreak of COVID-19, and reflect the institution’s size, complexity and activities.”