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New York Financial Regulator Requires COVID-19 Risk Assessment, Operational Planning

March 19, 2020 By Michael Young and Amy Mushahwar

Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires written responses “as […]

Filed Under: Licensing, Mortgage Loans, State Law Tagged With: #NYDFS, Covid-19

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

March 16, 2020 By Anoush Garakani

On March 13, 2020, the New York Department of Financial Services (“NYDFS”) adopted, on an emergency basis, amendments (the “Emergency Adoption”) to the final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations (the “Final Rules”), to extend the transition period for compliance with the Final Rules by an additional 90 […]

Filed Under: Consumer Loan, Mortgage Loans, Mortgage Servicing Tagged With: #NYDFS, #Part419, HELOC, Mortgage Servicing, Servicing

New York Proposes Licensing Consumer Debt Collectors

February 7, 2020 By Consumer Finance Team

A&B ABstract:  On January 21, 2020, New York Governor Andrew Cuomo proposed a measure to license consumer debt collectors as part of his budget bill. If enacted, the measure would require any person acting as a “consumer debt collector” in New York to obtain a license from the New York Banking Superintendent. Effective October 1, […]

Filed Under: Debt Collection, Licensing, State Law Tagged With: #NYDFS

NYDFS Issues Final Mortgage Loan Servicer Business Conduct Rules (Part 419)

January 28, 2020 By Morey Barnes Yost, Nanci Weissgold and Anoush Garakani

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 […]

Filed Under: Mortgage Loans, State Law Tagged With: #NYDFS, #Part419

New York Proposes Guidance for Regulated Virtual Currency Licensees

January 23, 2020 By Consumer Finance Team

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 […]

Filed Under: Fintech, Licensing, State Law Tagged With: #NYDFS, #virtualcurrency

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