NYDFS Reaches Agreements with Four Banks on New Symphony Chat & Messaging Platform

Electronic Records Data Collection / Aggregation NYDFS

On September 14, the New York State Department of Financial Services (NYDFS) announced that it had reached agreements with four financial institutions on record-keeping requirements and other protections intended to help ensure the institutions’ responsible use of the new Symphony Communications LLC (Symphony) chat and messaging platform. NYDFS had recently expressed concerns that certain Symphony features, such as its promise of “Guaranteed Data Deletion,” could hinder regulatory investigations on Wall Street. Under the agreements, Symphony will retain for seven years a copy of all electronic communications sent through its platforms to or from the four banks, and the banks will store duplicate copies of the decryption keys for their messages with independent custodians.