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A new law in New York took effect on June 11, 2025, requiring banking organizations, licensed lenders, and mortgage bankers provide a disclosure pamphlet titled “What Mortgage Applicants Need to Know” (the “Pamphlet”)....more
On January 14, Governor Kathy Hochul announced new proposals to protect New York consumers as part of her 2025 State of the State. Her proposals included legislation to: (i) combat algorithmic price discrimination by...more
The New York State Department of Financial Services issued its final rule on February 1, 2023, implementing the state's new Commercial Finance Disclosure Law. Commercial financing providers that are subject to the law have a...more
On September 14, 2022, the New York Department of Financial Services (the "DFS") released proposed regulations implementing the New York Commercial Finance Disclosure Law (the "CFDL"). The proposed regulations are open to...more
We reported last year on New York’s newly enacted commercial finance disclosure law and the legislature’s quick pivot thereafter, expanding the law’s reach to all loans up to $2,500,000 - a change from the previous limitation...more
The New York Department of Financial Services has issued a proposed regulation to implement S 5470–B, which requires consumer-like disclosures for “commercial financing” transactions of $2.5 million or less. The proposed...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
As Hogan Lovells previously reported, the New York State Department of Financial Services (NYDFS) has launched a significant initiative to impose detailed cybersecurity requirements on covered financial institutions. On...more
We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more
The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more