N.Y. Comp. Codes R. & Regs. tit. 3, § 409.4
(a) Notwithstanding section 409.3 of this Part, any student loan servicer required to obtain a license under that section, that is engaged in the business of servicing student loans prior to October 9, 2019 and that on or before such date submits a complete application pursuant to that section, shall be deemed to possess a temporary license to continue its engagement in the business of student loan services subject to the conditions and limitations set forth in subdivision (b) of this section.
(b) Temporary license.