News & Analysis as of

NYDFS Disclosure Requirements

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Troutman Pepper

With Delayed Federal Action on Mandatory Climate Disclosures, States and Regulators Fill the Void

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In the absence of comprehensive federal action, states and regulators are enacting legislation and issuing guidance requiring climate-related disclosures, stepping in to fill the void left by the U.S. Securities Exchange...more

Clark Hill PLC

Right To Know - January 2024, Vol. 13

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Cyber, Privacy, and Technology Report - Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed....more

Alston & Bird

Consumer Finance ABstract 2023 Year-End Reprise

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As we reflect on the previous year and look toward the new year, we thought you’d appreciate our top 20 most-read Consumer Finance ABstract posts from 2023...more

Wiley Rein LLP

Cybersecurity in 2024: Ten Top Issues to Consider

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As we enter the New Year, Wiley has looked back at the top cyber issues for 2023 and what they mean for 2024. Last year, we saw the rollout of the National Cybersecurity Strategy—which outlined a new era of cyber oversight—as...more

BCLP

New York’s Detailed Commercial Finance Disclosure Requirements Take Effect

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Compliance with the requirements of New York Financial Services Law sections 801-811 (the Commercial Finance Disclosure Law or “NYCFDL”) as implemented by the New York Department of Financial Services (“DFS”) becomes...more

Wiley Rein LLP

Wireless Roundup (August 2023)

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FCC Seeks Comment on Revising Spectrum Sharing Rules for Non-Geostationary Orbit, Fixed-Satellite Service Systems: In this proposed rule, the Federal Communications Commission (FCC) requests comment on revisions to its rules...more

Goodwin

New York CRPTO Bill Would Prohibit Many Digital Asset Activities and Impose Sweeping Market Structure Changes

Goodwin on

On May 5, 2023, New York Attorney General Letitia James released a bill for consideration by the New York State Legislature that would implement comprehensive and far-reaching regulation of digital asset activities in the...more

Alston & Bird

New York’s Commercial Finance Disclosure Law Set to Take Effect August 1, 2023

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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”)....more

Holland & Knight LLP

New York's "Small Business" Commercial Financing Disclosure Law

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If you are a nonbank finance company that makes commercial loans of $2.5 million or less in New York or represent such a company, this Holland & Knight alert is for you. There has been a growing concern expressed over the...more

Venable LLP

New York Commercial Financing Disclosure Requirements

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Providers of commercial financing that are subject to the New York State Commercial Finance Disclosure Law (CFDL) must provide disclosures to potential recipients of commercial financing at the time a specific offer of...more

Cadwalader, Wickersham & Taft LLP

New York Department of Financial Services Issues Regulations Regarding Commercial Finance Disclosures

The State of New York passed a law in December 2020 – the Commercial Finance Disclosure Law (“CFDL”), with an effective date of June 2021 – that prescribed required disclosures for commercial finance transactions that are...more

Goodwin

Federal Reserve and OCC Release 2023 Bank Stress Test Scenarios

Goodwin on

On February 9, the Federal Reserve released its hypothetical scenarios for its 2023 bank stress tests, and on February 10, the OCC also released hypothetical economic and financial market scenarios to be used by covered...more

Goodwin

New York Finalizes Commercial Financing Disclosure Regulations

Goodwin on

On February 1, 2023, the New York State Department of Financial Services (DFS) adopted final regulations relating to New York’s Commercial Finance Disclosure Law (CFDL), which requires providers of commercial financing,...more

Baker Donelson

Countdown Begins for Compliance with New York's Commercial Finance Disclosure Law as New York Issues Final Rule

Baker Donelson on

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

Buchalter

NY DFS Publishes Final Regulation Implementing Article 8, New York State’s Commercial Finance Disclosure Law

Buchalter on

Superintendent of Financial Services Adrienne A. Harris announced on February 1, 2023 that the New York State Department of Financial Services has adopted a final regulation relating to early disclosure requirements on...more

Ballard Spahr LLP

New York Department of Financial Services issues final regulations for consumer-like disclosures for commercial financing

Ballard Spahr LLP on

The New York Department of Financial Services (DFS) has issued final regulations implementing the state’s Commercial Finance Disclosure Law (CFDL) which requires consumer-like disclosures for “commercial financing”...more

Pillsbury Winthrop Shaw Pittman LLP

New York Finalizes Disclosure Requirements for Commercial Financing Transactions

New York has joined California and several other states in finalizing regulations requiring consumer-style disclosures for broad categories of commercial financing transactions....more

Dechert LLP

NYDFS Issues Guidance on Virtual Currency Custody Practices

Dechert LLP on

Citing a substantial increase in recent years in the demand for both virtual currencies and virtual currency custody services, the New York Department of Financial Services (NYDFS) on January 23, 2023 released its Guidance on...more

Troutman Pepper

New York Adopts Commercial Financing Transaction Disclosure Requirements

Troutman Pepper on

On February 1, the Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services completed the process for adopting a new regulation relating to disclosure...more

Mayer Brown

The Suspense Is Over – NYDFS Adopts Final Commercial Financing Disclosure Rules, Announces Effective Date, and Provides New...

Mayer Brown on

Small business financers and brokers (“providers”) active in New York are officially on notice to finalize their preparations to comply with New York’s Commercial Finance Disclosure Law (“CFDL”) by August 1, 2023, the new...more

Orrick, Herrington & Sutcliffe LLP

NYDFS finalizes commercial financing disclosures

On February 1, NYDFS adopted a final regulation (23 NYCRR 600) outlining disclosure requirements for commercial financing transactions in the state. Under the state’s Commercial Finance Disclosure Law (CFDL)—which was enacted...more

Latham & Watkins LLP

New York Department of Financial Services Issues Crypto Custody Guidance

Latham & Watkins LLP on

The Guidance clarifies the regulator’s expectations on safekeeping customer digital assets, and the disclosures that must accompany such arrangements. On January 23, 2023, the New York Department of Financial Services...more

Ballard Spahr LLP

How the New York Department of Financial Services (DFS) Regulates Virtual Currency, a Close Look with Special Guest Kaitlin Asrow,...

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After reviewing the licensing/chartering/approval structures that DFS uses for entities seeking to engage in virtual currency activities, we discuss the role of guidance in DFS’s regulation and oversight of virtual currency,...more

Shipkevich PLLC

New York Issues New Guidance on Crypto Currency Custodial Structures

Shipkevich PLLC on

On January 23, 2023, New York Department of Financial Services (DFS) released regulatory guidance to better protect customers in the event of virtual currency insolvency. The guidance is not binding, but rather persuasive...more

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