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NYDFS proposes e-apostille clarification and alternatives to board resolutions for office changes

November 6, 2026

On October 21, NYDFS proposed amendments to its supervisory policy on the legalization of foreign documents (G 7.1) and its procedure for applications to change an office location or principal office designation (G 105.2). Under the proposal, documents bearing an apostille, “including an e-apostille,” that a competent local authority in a Hague Convention country validly issued would require no further legalization. For office-change applications, the proposal would provide additional flexibility by allowing the application to be accompanied by a board resolution, or a statement that one was passed, be certified by the applicant’s secretary, and would extend the statement option to all applicants. It would also permit alternatives to a board resolution: a certified governing document delegating authority, a resolution of an authorized board committee, or a certified resolution delegating authority to specified persons, each accompanied by the relevant authorization or secretary’s certificate. According to the Regulatory Impact Statement, governing boards usually delegate these approvals, so the change would remove “the need for frequent waivers.” Comments are due December 21.