2012 Comment Letters (State)

High Volume Hydraulic Fracturing  New

2011 Comment Letters (State and Local)  

New York City: Upper West Side Zoning Restrictions

Dept. of Financial Services: Part 23

Debtor Nations in Default  

Decanting Trust Assets/Invading Principal

Private Right of Action for Improper Debt Collection  

Transfer or Assignment of a Mortgage Interest

Expansion of Martin Act Powers

Repeal of Prohibition of Payment of Interest on Demand Deposits  

Abandoned Multi-Family Dwellings  

Deceased Debtors  

Assignment of a Mortgage Interest  

Consumer Credit Fairness Act

New Jersey Taxation Nexus  

Dominican Consular Identification  

Debit and Credit Card Issuers - Sales and Use Taxes  

Notice to Tenants Upon Foreclosure of Leased Residential Property  

Standing to Commence an Action of Foreclosure  

Licensing of Third Party Debt Collectors  

Collecting from a Deceased Debtor  

Vehicle Lienholder Accountability Act  

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2011 Comment Letters (Federal)  

OCC: Deposit-Related Credit Products  

IRS: Reporting Interest Paid to Nonresident Aliens  

Federal Home Loan Bank Membership  

Registration of Municipal Advisors  

Debit Interchange

FDIC Assessments

NCCUSL Study Committee

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2011 Testimony (State and Local)    

State Assembly Foreclosure Bills   

New York City: Foreclosure Maintenance and Registration

State Agency Consolidation                  

New York City: Rating the Banks  

Residential Mortgage-Backed Securities
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2010 Comment Letters (New York State)     

Money Judgements  

CRA and the State Comptroller's Office

Safety Deposit Boxes
           
Review of Existing Regulations

Bank Tax Extension  

Check Cashing Geographic Limits  
         

Credit Unions and Municipal Deposits

Bank Tax Extension

Reciprocal Matching Deposit-Taking Programs

Resident Trust Tax

Increasing the Value of Property Shielded from Bankruptcy and Judgments

Preauthorized Electronic Funds Transfers

Requiring Mortgagors to Purchase Excess Flood Insurance

Crime Victims Credit Rating

Check Cashing Exemption


2010 Testimony (State)

Mortgage Foreclosure  

Availability of Legal Aid Services to Low-Income New Yorkers  

Authorizing Credit Unions to Accept Municipal Deposits 

New York City Council Resolution on Credit Unions and Municipal Deposits

2010 Comment Letters (Federal) 

FASB: Exposure Draft on Leases

FASB: Mark-to-Market Accounting

FDIC: Overdraft Protection Programs

Credit Union Business Lending Expansion as part of the Jobs Bill  

H.R. 1083: Business Activity Tax Simplification Act 

FDIC: Reclassification of Reciprocal Deposit Services as Core Deposits

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2009 Comment Letters (New York State)


Combined Article of Tax

Mortgage Foreclosure  

RESPA Changes

Dual Banking System

Part 38 Banking Board Regulations (Mortgage-related)

Use of Fees in Determining Over Credit Limit

Credit Reports and Fees

Unsolicited Loan Checks

Mortgage Bill of Rights

Foreclosure Proceedings

Agent for Service of Process/Foreclosure

Justice in Lending

Community Reinvestment Act (CRA)

Municipal Deposits for Credit Unions

Maturity Notices

New York City Tax Conformity

Debt Collection

Sales Tax Data Match
 

Exemption from Restraining Notices

Private Right of Action
                  Update: Private Right of Action

Overlimit Fees
                  Update: Overlimit Fees

Account Inactivity Fees

Disclosure of Social Security Numbers

Power of Attorney


2009 Testimony (New York State)

Mortgage Fraud

State Bank Tax Law

Debt Collection and Debt Settlement Practices

Banking Development Districts (BDD)


2009 Comment Letters (Federal)

Regulatory Reform, HR 4173

FDIC Prepaid Assessment Proposal

Interchange

FDIC Special Assessment

Overdraft Protection

Business Activity Tax

FASB: Other Than Temporary Impairment (3/27/2009)

FASB: Other Than Temporary Impairment

Pension Protection Act

Risk-based Capital Weightings

FDIC Risk-based Assessments

Overdraft Protection

Regulation Z

2009 Comment Letters and Testimony (Local)

Bank Robberies and Bandit Barriers

Bandit Barriers (Testimony) -- New York City

Bank Tax Conformity -- New York City

Bandit Barriers - New York City

Tenants' Rights in Event of Foreclosure/Property Maintenance - New York City
 

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2008 Comment Letters (New York State)

Definition of Resident for State's Personal Income Tax

Universal Default

ATM Transaction Denial Fees

Mortgage Recording Tax (September 2008)

Mortgage Lending

Student Lending, Accountability, Transparency, and Enforcement Act (SLATE)

Power of Attorney

ATM Transaction Denial Fees (February 2008)

Check Cashing

Credit Unions and the Linked Deposit Program
 

High Cost Home Lending


2008 Testimony (New York State)

Impact of State's New Mortgage Lending Law

Governor's Bill on Mortgage Lending
                Michael P. Smith Testimony
                John M. Scarchilli Testimony        


Statement on Executive Budget 2008-2009

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2007 Comment Letters (New York State)


Bank and REIT Taxes

Universal Default
Governor's Spitzer's VETO Message: Universal Default

IOLA

ATM Surcharges on Foreign Bank Accounts

Adverse Credit Actions Due to Identity Theft

Wild Card

Credit Score Determination

Linked Deposit Programs

Credit Card Transaction Forms

Short Form Power of Attorney
Governor Spitzer's VETO Message: Short Form Power of Attorney

Use of Social Security Numbers
Governor Spitzer's VETO Message: Use of Social Security Numbers

Definition of Industrial Bank


2007 Memoranda in Opposition

Universal Default, June 29, 2007

Late Fees, May 22, 2007

Credit Scores, February 13, 2007

Late Fees, February 13, 2007

ATM Fees, February 5, 2007

DTF Bank Tax Report
 

2007 Testimony

NYBA's Testimony regarding the 2009 Executive Budget

NYBA's Testimony before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, and Oversight, Analysis and Investigation on subprime lending practices.

Testimony by John Bryant, President of Operation Hope before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, and Oversight, Analysis and Investigation on subprime lending practices.

NYBA's Testimony before the NYS Senate Standing Committee on Consumer Protection, the NYS Assembly Standing Committee on Consumer Affairs and Protection, and the NYS Assembly Committee on Banks on the practices of credit card companies.

NYBA's Testimony before the NYS Senate Finance Committee and the NYS Assembly Ways and Means Committee on the proposed Bank Tax increases.

2007 Comment Letters (Federal)

NYBA's comments on garnishment of exempt federal benefits

NYBA's comments to the Office of Thrift Supervision on Unfair or Deceptive Practices (UDAP)

NYBA's comments on IRS proposed rulemaking on Section 67 Limitations on Trusts and Estates

NYBA's letter to Senators Schumer and Clinton opposing the Chambliss Amendment to the Farm Credit Bill

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2006 Testimony

NYBA's Statement at the NYS Assembly Banks and Consumers Affairs Committees Hearing on Financial Services for Low-Income Consumers

NYBA's Statement at the NYS Assembly Banks Committee Hearing on Banks' Discontinuance of Money Service Business Accounts
 

2006 Comment Letters

FDIC Proposal regarding risk differentiation frameworks and the base assessment rate schedule.

OTS Proposal regarding stock benefit plans in mutual-to-stock conversions and mutual holding company structures.

2006 New York State Legislative Comment Letters to Governor Pataki
Including: compensating use taxes paid on certain credit card accounts; examination intervals; credit line mortgages; information subpoenas; certain trust acquisitions; executive officers of savings banks; licensing of check cashers; and ATM lighting

FASB EITF Issue 06-4 "Accounting for Deferred Compensation and Postretirement Benefit Aspects of Endorsement Split-Dollar Life Insurance Arrangements"

FASB Proposal on Employers' Accounting for Defined Benefit and Other Plans

Federal Regulators' Proposed Guidance on Concentrations in Commercial Real Estate
 

New York Attorney General's Proposed Rulemaking on Registration of Charitable Entities

Amendments to the Deposit Insurance Assessment System

2005 Testimony

Banking Development Districts

Consumer Privacy

Privacy/Identity Theft (New York City)

Privacy/Identity Theft (New York State)

Privacy/Use of Social Security Numbers (New York State)

Overdraft Fees and Bounce Protection Programs (New York State Banking Dept.)

2005 Comment Letters

FDIC re Wal-Mart Bank Deposit Insurance Application

Privacy/Identity Theft

FHLB Letters of Credit

Transfer on Death Security Registration