Someone on the list must know this...

If a city / town / village clerk in New York wished to put vital
records online * prior to the restricted dates *, would this be
considered illegal by the NYS Department of Health?

A non-lawyer with experience in vital records tells me there is no way
that even an index would ever be allowed because the clerks have
custody of the records but DOH is the owner.

Any authoritative guidance would be appreciated.

-- 
Bob Sullivan
Schenectady Digital History Archive
<http://www.schenectadyhistory.org/>
Schenectady County (NY) Public Library