It would depend on your authorization and if your institution has met the exemptions. At $600m I would doubt that the exemptions would be met, I would suggest contacting your legal area.
(c) Covered Entity means any Person operating under or required to operate under a license, registration,
charter, certificate, permit, accreditation or similar authorization under the Banking Law, the Insurance Law or
the Financial Services Law.
for exemptions:
CLICK HERE