NYDFS Extends Transition Period for Part 419 Compliance by Additional 90 Days

A&B Abstract: New York is one of the first states that enacted laws requiring consumer-style disclosures for commercial financing transactions (the “New York Law”). Previously, the New York Department of Financial Services (“NYDFS”) issued guidance stating that compliance with the requirements would be delayed until it issued final implementing regulations. Those final regulations were published […]

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In early March, the New York Department of Financial Services (NYDFS) announced a settlement involving a $1.5M penalty and mandatory remediation in response to a mortgage lender’s alleged failure to report a cyber breach, and other alleged cybersecurity failures. This enforcement action marks the second public enforcement action under 23 NYCRR Part 500 (the “Cybersecurity Regulation”) (see […]

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A&B ABstract: On September 1, 2020, the Deputy Superintendent of the New York Department of Financial Services (“NYDFS”), issued guidance (the “Guidance”) to New York State regulated mortgage lenders and servicers (collectively referred to as “Servicers”) regarding fees paid to register mortgages in default. The Guidance reminds Servicers of the restrictions on fees and charges […]

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The New York Department of Financial Services (“NYDFS”) has issued final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations.  Our January 24 client advisory provides a full analysis of the changes, which include: New provisions governing affiliated business arrangements; Expanded restrictions on servicing fees (including property valuation fees); A broader […]

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A&B ABstract Since the New York Department of Financial Services (“NYDFS”) finalized regulations for virtual currency firms in 2015, several regulated virtual currency licensees (“Licensees”) have sought permission to issue new virtual currencies (i.e., coins) in addition to those included in their initial license applications. On December 11, 2019, NYDFS issued Proposed Guidance in response […]

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