[authors: Jeremiah P. Sheehan, Marcia D. Alazraki, and Jay B. Martin]
The offices of the New York Department of Financial Services in downtown Manhattan have been closed due to damage to the building resulting from Hurricane Sandy. It is currently anticipated that the office at State Street, which houses Banking Department staff, executive staff, and some Insurance Division employees, may open to a limited number of employees in the near future. The Beaver Street office, which houses most Insurance Division staff, is not expected to be available until after Thanksgiving.
Temporary satellite offices have been opened at locations in Brooklyn, Manhattan, and Nassau County. Attempts have been made to put employees of the same Bureau in the same location where possible. We understand that the staff have telephones and desks and that laptop computers are being configured. It is not clear how broad access will be to electronic records, but there is no access to paper records or documents on the hard drives of computers in the Beaver Street office. Email access was recently restored, but we understand that it relates to recent emails only.
The current situation is expected to preclude approval of most pending filings. Only high-priority matters requiring action by year-end are likely to be given precedence.
Regarding new filings, the uncertainty about the Beaver Street office suggests that paper filings should not be made at this time, since they are highly unlikely to be considered and have the potential to be lost or misdirected. For similar reasons, new filings should be held until the office is open if the timing and deadline involved so permit. Where a filing must be made, the DFS staff person involved should be contacted by email regarding where and how it should be sent. We stand ready to try to provide assistance in this regard.
The DFS offices in Albany—including the Office of General Counsel (insurer formation, licensing, and related matters), Licensing Bureau (producer, adjuster, and other non-insurer licensing), Life Bureau and Health Bureau (rate and form filings), and Property Bureau (UCAA licensing filings involving property-casualty insurers)—remain open.