NYDFS recently issued Proposed Guidance “to New York State-regulated banking organizations and regulated non-depository financial institutions to notify them of the Department’s expectation that they update their framework for the review and assessment of the character and fitness of their directors, senior officers, and managers, both upon onboarding and on an ongoing basis.”

The Proposed Guidance applies to “each member of a Covered Institution’s board of directors, board of trustees and/or board of managers, as applicable, and each senior officer of a Covered Institution (‘Designated Persons”). The term ‘senior officer’ refers to every officer who participates or has authority to participate (other than in the capacity of a director) in major policy-making functions of a Covered Institution.” The link to the entire Proposed Guidance is here. There is a comment period running through June 30, 2023.

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