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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
The New York Department of Financial Services (NYDFS) promulgated its long-awaited final rule regarding commercial financing disclosures, which applies to transactions of $2.5 million or less, on February 1, 2023. The state’s...more
Lenders will soon be required to collect detailed demographic and financial data on commercial credit applicants and report this data to regulators. The NYDFS issued a proposed rule that will require New York banks to...more
On October 20, the New York Department of Financial Services (NYDFS) published a notice in the New York State Register announcing that it has issued a proposed regulation to implement S 5470-B, which requires disclosures for...more
In the absence of a federal law requiring disclosures be provided to small businesses, regulators in California in 2018, and now New York, have jumped into the void. With the Enactment of the New York Commercial Finance...more
On September 21, 2021, New York’s Department of Financial Services (DFS) announced proposed regulations that clarify the small business Truth in Lending disclosure requirements that go into effect on January 1, 2022. The...more