Alston & Bird Consumer Finance Blog

Consumer Finance

Expansion of New York’s Community Reinvestment Act Via New Regulation

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Last week, the New York State Department of Financial Services (DFS) announced a new regulation designed to ensure that licensed nonbank mortgage bankers in New York (“mortgage lenders”) meet the needs of the communities they serve in the state, particularly low- and moderate-income (LMI) neighborhoods and borrowers. Under New York law, “low-income” means income that is less than 50% of the area median income, in the case of an individual, or a median family income that is less than 50% of the area median income, in the case of a geography. Further, “moderate-income” means income that is at least 50% and less than 80% of the area median income, in the case of an individual, or a median family income that is at least 50% and less than 80% of the area median income, in the case of a geography.

By way of background, in November 2021, New York amended the state’s Community Reinvestment Act (CRA), which at the time mirrored the federal Community Reinvestment Act, to expand coverage to New York state-licensed mortgage bankers. This made New York the third state (after Illinois and Massachusetts) to pursue such action.

The new regulation, effective July 7, 2026, takes things further by imposing following parameters and requirements on mortgage lenders as set forth below.

Origination Threshold

Non-depository mortgage bankers that have made at least 200 HMDA-reportable originations in the preceding year are subject to performance evaluation under the new regulation and will receive a rating of Outstanding, Satisfactory, Needs Improvement, or Substantial noncompliance.

No Branches, No Problem

A mortgage banker with one or more branches within the state must delineate one or more branch-based assessment areas for evaluating performance. However, “branchless” lenders will be evaluated based on where they do a substantial portion of their business. Specifically, the lender must delineate a lending-based assessment area in each MSA or nonmetropolitan area in which it originated, in each of the two preceding calendar years, at least 100 mortgage loans outside of any branch-based assessment areas.

Performance Tests

The regulation imposes a lending test and service test on non-bank mortgage lenders, to arrive at a performance rating. Notably, the DFS, when reviewing a mortgage lender’s change of control, branch, or other application, will consider the mortgage lender’s record of CRA performance.

  • Lending test. The lending test assesses how well mortgage bankers serve all borrowers and neighborhoods within their assessment areas, particularly LMI communities. The lending test considers the geographic distribution of loans in LMI tracts and to LMI borrowers. In addition, the lending test considers the lender’s innovative and flexible lending practices, carried out safely and soundly, to meet the needs of these communities.
  • Service test. The service test evaluates whether mortgage lenders offer programs and services that promote community development. Unlike banks, however, mortgage bankers will not be required to make community development investments or grants, recognizing the differences in how these institutions operate. Nevertheless, mortgage lenders will be evaluated on the extent and innovativeness of their community development services, qualified investments, community outreach, marketing, and educational programs; each of which are defined terms under the regulation.

Discrimination and Other Illegal Credit Practices

The evaluation of a mortgage banker’s performance in meeting the credit needs of the community is adversely affected by evidence of discriminatory or other illegal credit practices in any geography by the mortgage lender, including violations of (1) Section 5 of the FTC Act, (2) Section 8 of RESPA, (3) TILA’s right of rescission, (4) HOEPA or New York’s high cost lending law, or (5) ECOA, Fair Housing Act or section 296-a of New York Executive Law.

Given the above, New York-licensed mortgage lenders should prepare for these CRA obligations by conducting preliminary analysis of their lending in LMI census tracts and to LMI borrowers, to ensure that both marketing efforts and loan product offerings are meeting the needs of these communities. While federal redlining enforcement may currently be deprioritized, state-level CRA inquiries and investigations are likely to ramp up. Alston & Bird is able to assist mortgage lenders with proactive efforts to ensure compliance with New York’s CRA law.

Commercial Financing Disclosure Requirements and Exemptions

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What Happened

In a development that has not attracted sufficient industry attention, eleven commercial financing laws enacted to date require providers of certain types of commercial financing to disclose key terms to small businesses and other covered entities before a transaction is consummated. These requirements apply to providers of commercial financing transactions that are in amounts below certain thresholds, such as sales-based financing, closed-end and open-end commercial loans, factoring transactions, lease financing, accounts receivable purchases, and asset-based lending arrangements.

Why It Is Important

This post summarizes the salient elements of the of these eleven state laws that have been enacted to date in California, Connecticut, Florida, Georgia, Kansas, Louisiana, Missouri, New York, Texas, Utah, and Virginia, respectively, including a brief description of the coverage of the statutes as well as the notable exemptions and applicable disclosure and registration requirements. Some of these statutes also impose registration requirements upon lenders, and all of them subject violators to substantial penalties.

California

The California disclosure requirements took effect on December 9, 2022. With respect to California’s law, persons providing commercial financing (including small business loans and merchant cash advances) to recipients “whose business is principally directed or managed from California” are required to provide recipients with consumer-like disclosures, after the California Department of Financial Protection and Innovation issued final regulations in June 2022 to implement the California Commercial Financing Disclosure Law (“CCFDL”). Commercial financing providers are required to disclose to the recipient at the time of extending a specific commercial financing offer specified information relating to the transaction and to obtain the recipient’s signature on that disclosure before consummating the commercial financing transaction. The CCFDL exempts, among others, regulated depository institutions (banks, credit unions, etc.), transactions greater than $500,000 and real estate-secured commercial loans or financings. The California law otherwise applies to, among other things, commercial loans, certain commercial open-end plans, factoring, merchant cash advances, and commercial asset-based lending. Under the California law “provider” is primarily limited to entities that extend offers of commercial financing, such as lender/originators, but also includes a non-bank partner in a marketplace lending arrangement who facilitates the arrangement of financing through a financial institution.

Connecticut

On June 28, 2023, Connecticut enacted “An Act Requiring Certain Financing Disclosures,” which requires (1) providers offering “sales-based financing” (a/k/a revenue-based financing) in amounts of $250,000 or less to provide specified disclosures to applicants; and (2) mandates that providers offering sales-based financing register annually with the Connecticut Department of Banking starting by October 1, 2024. The Connecticut law authorizes the state banking commissioner to adopt promulgating regulations, and the law took effect on July 1, 2023. The Connecticut law applies to providers of commercial financings and defines “provider” as “a person who extends a specific offer of commercial financing to a recipient and includes, unless otherwise exempt … a commercial financing broker.” “Commercial financing” means any extension of sales-based financing by a provider not exceeding $250,000. Under the statute, “sales-based financing” is a “transaction that is repaid by the recipient to the provider over time” (1) as a percentage of sales or revenue, in which the payment amount may increase or decrease according to the recipient’s sales or revenue, or (2) according to a fixed payment mechanism that provides for a reconciliation process that adjusts the payment to an amount that is a percentage of sales or revenue. Notably, the Connecticut law exempts the following entities and transactions: banks, bank holding companies, credit unions, and their subsidiaries and affiliates; entities providing no more than five commercial financing transactions in a 12-month period; real estate-secured loans; leases; purchase money obligations; technology service providers acting for an exempt entity as long as they do not have an interest in the entity’s program; transactions of $50,000 or more to motor vehicle dealers or rental companies; transactions offered in connection with the sale of a product that the person manufactures, licenses, or distributes.

Florida

Effective July 1, 2023, Florida enacted the Florida Commercial Financing Disclosure Law, which requires covered providers to furnish consumer-oriented disclosures to businesses for certain commercial non-real estate secured financing transactions exceeding $500,000. The Florida law applies to providers of commercial financing transactions and defines “provider” as a “person who consummates more than five commercial financings” in Florida during any calendar year. “Commercial financing transactions” include commercial loans, open-end lines of credit, and accounts receivable purchase transactions. The Florida law exempts the following entities and transactions: federally insured depository institutions, their subsidiaries, affiliates, and holding companies; licensed money transmitters; real estate-secured loans; loans exceeding $500,000; leases; and certain purchase money transactions. All financings made on or after January 1, 2024, must comply with this requirement.

Georgia

Effective January 1, 2024, Georgia amended its Fair Business Practices Act to require certain providers of commercial financings of $500,000 or less to furnish TILA-like disclosures to small-business borrowers before the consummation of the transactions. Transactions greater than $500,000 are exempt from the disclosure requirements. The Georgia law defines “provider” as “a person who consummates more than five commercial financing transactions” in Georgia during any calendar year, including participants in commercial purpose marketplace lending arrangements. “Commercial financing transactions” include both closed-end and open-end commercial loans as well as accounts receivable purchase transactions but do not include real estate-secured transactions. The Georgia law exempts federally insured depository institutions and their subsidiaries, affiliates, and holding companies; Georgia-licensed money transmitters; captive finance companies; and institutions regulated by the federal Farm Credit Act. Purchase money obligations are also exempt.

Kansas

The Kansas Commercial Financing Disclosure Act, which took effect July 1, 2024, applies to “commercial financing transactions” of $500,000 or less, defined to include any commercial loan, commercial open-end credit plan, lines of credit, and accounts receivable purchase transaction, with a business located in Kansas. A provider subject to the Kansas Act must disclose the following to the recipient of financing before, or at the time of, consummation: total amount of funds provided to the recipient; total amount of funds disbursed to the recipient; total of payments made to the provider; total dollar cost of financing for the recipient; manner, frequency and amount of each payment (or estimates if these terms may vary, along with the provider’s methodology for calculating variable payments and circumstances where payments may vary); and prepayment costs or discounts.

Louisiana

Effective August 1, 2025, Louisiana law requires provides of “revenue-based financing transactions,” defined as “an agreement under which a person engaged in a commercial enterprise sells or agrees to forward a percentage of sales, revenue, or income, and the person’s payment obligation increases and decreases according to the volume of sales made or revenue or income received,” to provide written disclosures to recipients of financing. Notably, Louisiana’s law is the first state commercial financing disclosure law that does not exempt any types of entities or transactions, regardless of dollar amount.

Missouri

Missouri Senate Bill 1359, which includes provisions for commercial lending disclosures, went into effect on February 28, 2025. The Missouri law prescribes that several disclosures be made for commercial financing transactions and applies to “providers” of commercial financing transactions, defined as a “person who consummates more than five commercial financings” to a business located in Missouri in any calendar year. “Commercial financing transactions” include any unsecured and secured commercial loan, accounts receivable purchase transaction, commercial open-end credit plan or each to the extent the transaction is a business purpose transaction. Exemptions from the Missouri law include the following entities and transactions: a depository institution or a subsidiary or affiliate; a service corporation to a depository institution that is owned and controlled by same and regulated by a federal banking agency; a lender regulated by the federal Farm Credit Act; real estate-secured loans; a lease; a licensed money transmitter; loans exceeding $500,000; and certain purchase money transactions. This law also contains a registration requirement for brokers.

New York

The New York Commercial Financing Disclosure Law (“NYCFDL”) took effect August 1, 2023, and is substantially similar to the California requirements. It requires “providers” of commercial credit to provide Truth-in-Lending Act-like disclosures to applicants at the time it extends a specific offer of the commercial financing in amounts of $2,500,000 or less. “Providers” include both lenders and brokers. The NYCFDL applies to closed end financing, open-end financing, sales-based financing, including merchant cash advances and factoring transactions. The NYCFDL provides a de minimis exemption, “for any person or provider who makes no more than five commercial financing transactions in [New York] in a twelve-month period.” Further, “Financial institutions”, which include banks, and certain other chartered depository institutions authorized to conduct business in New York, are also exempt from the new commercial loan disclosure law, but the subsidiaries or affiliates of such exempt financial institutions are not exempt. Commercial financings over $2,500,000 are exempt from the law as are transactions secured by real property. The obligation to provide disclosures apply if the financing recipient’s business is “principally directed or managed from New York.”

Texas

On May 28, 2025, the Texas legislature passed a “commercial sales-based financing” bill, known as House Bill 700, and Governor Greg Abbott signed the bill into law on June 20, 2025. Among other things, the Texas law requires disclosure of sales-based financing terms to recipients, and, starting December 31, 2026, registration for all sales-based financing providers and brokers with the Texas Office of Consumer Credit Commissioner. Registrants must renew their registrations annually by January 31. The legislation exempts from its requirements the following entities: banks (specifically including out-of-state banks) and their subsidiaries and affiliates, certain companies that provide tech services to exempt entities, lenders regulated under the Farm Credit Act, real property secured sales-based financing, true (operating) leases, and certain commercial sales-based financing agreement or commercial open-end credit plan of $50,000 or more. Financings greater than $1 million are exempt from the disclosure requirement. Unlike any other current state law, the Texas law also contains a provision prohibiting sales-based financing providers and brokers from establishing a mechanism for automatically debiting a recipient’s deposit account unless the provider or broker holds a validly perfected security interest in the recipient’s account under the Texas UCC, with a first priority against the claims of all other persons. Most provisions of the law became effective on September 1, 2025, except for the provider and broker registration requirement.

The Texas legislation, while part of a growing trend of augmented state regulation of commercial non-real estate secured commercial financing, is far more burdensome than other similar state laws enacted to date.

Utah

Effective January 1, 2023, the Utah law requires providers to register with the Utah Department of Financial Institutions and maintain such registration annually. Further, prior to consummation of the commercial financing, providers must, among other things, disclose to recipients: (i) the total amount of funds provided to the business; (ii) the total amount of funds disbursed to the business; (iii) the total amount paid to the provider under the financing; (iv) the manner, frequency and amount of each payment (or if the amount of each payment may vary, the manner, frequency and estimated amount of the initial payment); (v) information regarding prepayment of the financing; and (vi) the amount the provider paid to the broker, if applicable. The Utah law does not apply to consumer purpose transactions, real estate-secured transactions or transactions with loan amounts greater than $1 million—or if the provider makes five or fewer Utah commercial financings in any calendar year.

Virginia

The Virginia law, which took effect on July 22, 2022, includes some of the same type of disclosure requirements that other states discussed above have adopted, but it is limited to sales-based financing. Notably, the Virginia law requires sales-based financing providers to make disclosures of the financing terms on a prescribed form at the time the provider offers sales-based financing to a recipient—and requires them to register with the Virginia State Corporation Commission. The law exempts sales-based financings in amounts over $500,000 and contains a de minimis exemption for a person that enters into no more than five “sales-based financing” transactions in any 12-month period.

What to Do Now

It is anticipated that other states will enact similar laws in the future that will impact small balance commercial lending. Lenders must either comply with these nettlesome laws or structure their transaction to avoid triggering them.

FAPA Is Here to Stay: Understanding the NY Court of Appeals’ Retroactivity Ruling and Its Impact on Foreclosures

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On November 25, 2025, the New York Court of Appeals—the highest court in the state of New York—issued a decision in Article 13, LLC v. LaSalle National Bank Association, holding that New York’s Foreclosure Abuse Prevention Act (FAPA) applies retroactively to all foreclosure actions in which a final judgment of foreclosure and sale has not been enforced.

What Happened?

In December 2022, New York enacted FAPA to close a perceived loophole under prior case law that allowed the holders of mortgage notes to reset the statute of limitations on foreclosure. Previously, a noteholder could show that that the mortgage was not validly accelerated, or was voluntarily deaccelerated, which would reset the statute of limitations. Under FAPA, however, parties are estopped from asserting that an invalid acceleration or voluntary deacceleration reset the statute of limitations.

Two years before FAPA was enacted, Article 13 LLC—a junior mortgage holder on a property—brought a quiet title action before a federal district court seeking to cancel a senior mortgage as time-barred under the statute of limitations. Relying on pre-FAPA case law, the holder of the senior mortgage argued the statute of limitations had not run because the mortgage had not been validly accelerated. Mid-litigation, New York enacted FAPA, and the district court held that FAPA estopped the senior mortgage holder from making this argument.

The case went on appeal to the U.S. Court of Appeals for the Second Circuit, which certified the question of whether FAPA applied retroactively to the New York Court of Appeals. Based on FAPA’s plain language, the New York Court of Appeals first held that FAPA applies retroactively, at least for foreclosure actions in which a final judgment or foreclosure and sale has not been enforced. It then held that the retroactive application of FAPA does not violate substantive or procedural due process under New York’s constitution. The Court explained that retroactive application does not offend due process because it does not impair the vested rights of holders, which in the typical situation, are aware for years of the invalid acceleration and have every opportunity to take timely action to enforce their rights.

Why is it Important?

The New York Court of Appeal’s decision is significant because in cases where a prior foreclosure action was commenced (triggering the statute of limitations) but later discontinued without an express judicial determination that acceleration was invalid, lenders are now estopped from reviving the loan after the limitations period has expired. This puts an end to an old practice and represents a major shift in the mortgage foreclosure industry.

For mortgage servicers, this means that before proceeding with a foreclosure, they must first evaluate aged or delinquent loans to reassess whether pursuing foreclosure is viable. This is particularly true when prior foreclosures have been voluntarily discontinued, dismissed, or left dormant. Attempting to re-file may now lead to outright dismissal under FAPA.

For participants in the secondary market, it is now important to employ heightened diligence to determine whether mortgages held in trust are still enforceable. Mortgages or entire portfolios that were previously viewed as recoverable through renewed foreclosure actions may now be worth only their collateral value or even nothing at all.

What Do You Need to Do?

Mortgage servicers should review their foreclosure strategies, including their allocation of litigation resources, as time-barred loans may require alternative resolution strategies such as settlements or charge-offs.

Meanwhile, RMBS trusts and other holders of distressed mortgage portfolios should consider whether to audit their portfolio to identify mortgages with prior foreclosure actions that may now be time barred under FAPA. Or, in the case that they are junior lienholders, they should consider whether they can leverage FAPA in quiet title actions to cancel more senior mortgages that are now time-barred.

CFPB Rescinds Registry for Covered Nonbank Entities

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What Happened?

In the October 29 Federal Register, the Consumer Financial Protection Bureau issued a final rule rescinding its previous rule relating to the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule, which imposed obligations on nonbank entities that offer or provide a consumer financial product or service. As a result, covered nonbanks will no longer be required to registered with the Bureau or provide information about certain public Federal, State, or local written orders imposing obligations on the nonbank based on violations of certain consumer protection laws (among other obligations we discussed in a previous post).

In the same Federal Register issue, the Bureau also issued notice of its intent to rescind: (a) amendments to its rules of practice governing adjudication proceedings; and (b) a proposed rule regarding the registry of supervised nonbanks that use form contracts to impose terms and conditions that seek to waive or limit consumer legal protections.

Ohio Mortgage Rules Have Changed: Servicing Now Covered

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What Happened?

Effective September 19, 2025, the Division of Financial Institutions (“Division”) of the Ohio Department of Commerce adopted amended rules (the “Amended Rules”) under the Ohio Residential Mortgage Lending Act (“RMLA”) to add and clarify obligations for mortgage servicers.

Why Does it Matter?

The Amended Rules are largely intended to provide clarity to mortgage servicers regarding the application of the RMLA to mortgage servicing businesses, and to implement procedures to prevent servicing problems. For entities licensed under the RMLA, the Amended Rules address registration of offices, unlicensed activity, recordkeeping, prohibited practices, servicing transfers, escrow payments, payment processing, error resolution, borrower requests for information, and a servicer’s obligations upon loss of license. The Amended Rules largely mirror the CFPB’s mortgage servicing rules (i.e., 12 C.F.R. Part 1024, Subpart C (Regulation X) and, to some extent, 12 C.F.R. Part 1026 (Regulation Z)).

Notably, an entity that violates the Amended Rules may be subject to penalties under the RMLA, which are up to $1,000 per day for each day a violation of law or rule is committed, repeated, or continued (and up to $2,000 a day of there is a pattern of repeated violations of law or rule).

Below, we highlight some of the most impactful provisions of the Amended Rules.

Amended Rules

  • Registration Requirements: The Division amended Section 1301:8-7-02 of the Ohio Administrative Code (the “OAC”) to require entities subject to the RMLA (mortgage brokers, lenders and servicers) to register each office location at which it transacts business.
  • Standards for Applications, License, and Registration: The Division amended Section 1301:8-7-03 of the OAC, to clarify that a mortgage broker, mortgage servicer, or loan originator cannot conduct business if they fail to renew their registration on or before December 31. (The Division indicated that it was amending the renewal date to correct a drafting error that incorrectly identified January 31 as the renewal date.)
  • Recordkeeping: The Division amended Section 1301:8-7-06 of the OAC, which relates to recordkeeping, to require a mortgage servicer to retain records that document actions taken with respect to a borrower’s account for four years following the date the loan is discharged or transferred to another servicer; and to maintain specified documents and data in a manner that facilitates compiling the documents and data into a servicing file within five days. (The rule does not expressly address maintenance of records of telephone calls with borrowers.) While the rule requires retention of the same records required under Regulation X (12 C.F.R. § 1024.38(c)), note that the retention period is much longer than Regulation X’s and does not exempt small servicers under Regulation X.
  • Prohibited Practices: The Division amended Section 1301:8-7-16 of the OAC, to add a list of actions specific to servicing that constitute improper, fraudulent, or dishonest dealings under Ohio Revised Code section 1322.40.  Specifically, the rule prohibits a servicer from, among other things:
    • assessing a borrower any premium or charge related to force-placed insurance unless the servicer: (i) has a reasonable basis to believe that the borrower has failed to comply with the residential mortgage loan contract’s requirement to maintain hazard insurance; and (ii) delivers or mails to the borrower a written notice at least 45 days before assessing such charge or fee;
    • misrepresenting or omitting any material information in connection with the servicing of a residential mortgage loan, including misrepresenting the amount, nature, or terms of any fee or payment due or claimed to be due on a residential mortgage loan, the terms and conditions of the servicing agreement, or the borrower’s obligations under the residential mortgage loan;
    • failing to apply payments in accordance with a servicing agreement or the terms of a note; (d) making payments in a manner that causes a policy of insurance to be canceled or causes property taxes or similar payments to become delinquent;
    • failing to credit a periodic payment to the borrower’s account as of the date of receipt, except when a delay in crediting does not result in any charge to the borrower or in the reporting of negative information to a consumer reporting agency (except where the servicer specifies in writing requirements for the borrower to follow in making payments, but accepts a payment that does not conform to the requirements, where the servicer has five days to credit the payment);
    • requiring any amount of money to be remitted by means which are more costly to the borrower than a bank or certified check or attorney’s check from an attorney’s account to be paid by the borrower;
    • charging a fee for handling a borrower dispute, facilitating routine borrower collection, arranging a forbearance or repayment plan, sending a borrower a notice of nonpayment, or updating records to reinstate a loan; or
    • pyramiding late fees.
  • Mortgage Servicing Definitions: The Division added Section 1301:8-7-35 to the OAC, which defines terms relevant for the provisions of other new sections (as discussed below), including: (a) “confirmed successor in interest,” “escrow account,” and “qualified written request,” which are consistent with Regulation X; and (b) “federal lending law” and “residential mortgage loan,” the latter of which is defined to limit the Amended Rules’ application to closed-end loans, consistent with Regulation X and Regulation Z.
  • Mortgage Servicing Transfers: The Division added Section 1301:8-7-36 to the OAC, to prohibit a transferee servicer from treating an on-time payment made to the old servicer within the 60-day period following the transfer of servicing. It also requires the old servicer to either forward the payment to the new servicer, or return it to the borrower and notify the borrower of the proper recipient. This rule generally mirrors 12 C.F.R. § 1024.33(c).
  • Escrow Accounts: The Division added Section 1301:8-7-37 to the OAC, which requires a mortgage servicer to: (i) make all required escrow payments in a timely manner, and (ii) timely return any payments due to the borrower. It also allows a servicer, if the borrower agrees, to credit any amount remaining in a borrower’s account to a new escrow account for a new loan. This rule generally mirrors 12 C.F.R. §§ 1024.34 and 1024.17(k).
  • Error Resolution Procedures: The Division added Section 1301:8-7-38 to the OAC, which establishes error resolution procedures that mirror the requirements of the CFPB mortgage servicing rules (12 C.F.R. § 1024.35).
  • Requests for Information: The Division added Section 1301:8-7-39 to the OAC, which establishes information request procedures that mirror the requirements of the CFPB mortgage servicing rules (12 C.F.R. § 1024.34).
  • Mortgage Servicer Obligations upon Loss of License: Finally, the Division added Section 1301:8-7-40 to the OAC, which provides that the revocation, suspension, or failure of a servicer to obtain or maintain a license does not affect a servicer’s obligations under a preexisting contract with a lender or borrower.

What To Do Now?

The Amended Rules significantly expand the requirements applicable to mortgage servicers subject to the RMLA. While many of the Amended Rules mirror those under the CFPB’s mortgage servicing rules, certain provisions impose additional obligations on mortgage servicers and/or apply to servicers that may otherwise be exempt from certain requirements under the CFPB’s mortgage servicing rules (e.g., small servicers). Accordingly, mortgage servicers should carefully review the Amended Rules and ensure that their policies, procedures, and controls are updated as appropriate to ensure compliance. Alston & Bird’s Consumer Financial Services Team is actively engaged and monitoring these developments and can assist with any compliance concerns regarding the changes imposed by the Amended Rules.