NYS Real Estate Finance Bureau: COVID-19 Relief Period Ends, eSubmission Portal Launches
Since March 2020, the New York State Department of Law’s Real Estate Finance Bureau (“REF”) has operated under temporary policies introduced during the COVID-19 state of emergency. These policies allowed flexibility in submitting offering plans, amendments, and related documents. REF has now announced that this “relief period” will officially end on January 7, 2026, as outlined in its December 23, 2025 guidance.
What Changes on January 7, 2026?
REF is modernizing its processes with the official launch of a paperless eSubmission Portal. Key updates include:
- Mandatory eSubmission: All offering plans, amendments, brokerdealer registration statements (M-10 Forms) must be submitted through the new portal
- Electronic Confirmations: Filing receipts and acceptance letters will no longer be issued on REF letterhead in PDF format. Instead, confirmations will be sent via email
- Digital Documentation Accepted: Scans or photocopies of documents; Electronic signatures (e.g., DocuSign) in place of wet ink signatures; Remote online notarization and sponsor affirmations in lieu of traditional notarization
Grace Period Until July 1, 2026
REF has provided a transition period for certain compliance requirements. Starting July 1, 2026, REF will begin enforcement actions for:
- Marketing or selling units under an expired or stale offering plan
- Failing to file price-change amendments before offering units at updated prices
- Missing deadlines for broker-dealer or salesperson registration filings
- Submitting amendments without current broker-dealer registration information
- Failing to file Policy Statement applications before offering or promoting real estate securities in or from New York State
Action Steps for Sponsors, Developers and Holders
If you plan to market, offer, or sell units on or after July 1, 2026, you should confirm that:
- Your offering plan is current and not stale
- Prices are up to date
- Necessary amendments and registrations are filed well before the deadline
Key Takeaways
- Temporary COVID-19 relief period ends January 7, 2026.
- New eSubmission Portal launches January 7, 2026: All filings must be electronic.
- Grace period until July 1, 2026: After this date, REF will begin enforcement actions for non-compliance.
- Sponsors should act now: Review offering plans, update prices, and file necessary amendments and registration documents well before July 1, 2026.
Contact Us
Please reach out to your attorney of record or contact us here with any questions or to discuss how these updates may impact your specific situation.
Written by: Lloyd F. Reisman and Zachary C. Rozycki, Co-op and Condo Law Practice.