New York State Executive Order No. 202.9 Re: Forbearances
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Continuing Temporary Suspension and Modification of Laws Relating to the Disaster Emergency Relating to 90 Day New York Bank Forbearance in Certain Circumstances

New York Governor Andrew Cuomo on March 21, 2020 signed Executive Order No. 202.9 (the “Order”) which, by its terms, provided for various types of financial relief to “persons or entities” who are suffering from “financial hardship” as a result of the coronavirus pandemic. This Order, which is dated March 21, 2020, remains in effect until April 20, 2020, unless terminated or extended prior to that date. The Order was broad in its purported scope of coverage and subject to a range of interpretations. A degree of clarification came on March 24, 2020 when the New York State Department of Financial Services promulgated emergency regulations (see NYCRR Part 119) which served to clarify certain aspects of the Order.

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