Testimony & Comment Letters

As one of New York State’s leading financial services trade organizations, NYBA promotes sound but progressive fiscal policies that advance commercial and community interests as well as individual initiatives. Our proactive approach to advocacy seeks to minimize regulation and encourage economic growth.  Legislative and regulatory relations are our top priority, with an emphasis on establishing and nurturing partnerships with political leaders who will work with us to ensure effective and beneficial change.  NYBA has a long and proud history of legislative and regulatory victories on behalf of the banking industry.

2019 Comment Letters (State)

Statement on Budget Hearing and Cannabis Banking
New York State Department of Financial Services’ Proposed Regulation Part 419 “Servicing Mortgage Loans: Business Conduct Rules”

2018 Comment Letters (State)

Draft Amendments to Corporations Subject to Tax Regulation and Metropolitan Business Tax Surcharge Regulation 

2018 Comment Letters (Federal)

Reconsideration of HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard

2017 Comment Letters (State)

Revised Cybersecurity Proposed Regulations
Financial Abuse of the Elderly Comments and Proposals

2016 Comment Letters (State)

Anti-Money Laundering Proposed Regulations
Cybersecurity Proposed Regulations
Abandoned Property Proposed Regulations

2015 Comment Letters (Federal)

Regulatory Reform – Senate / House

2015 Testimony (State and Local)

Auto Lending


2014 Comment Letters (State and Local) 
Mortgage Insurance Premium
Force-Placed Insurance
Proposed New 11 NYCRR 35, (Insurance Regulation 206)
Wild Card
STAR Exemptions
Standing in a Mortgage Foreclosure Action
Civil Practice Law and Rules
Foreign Business Jurisdiction
Subprime Home Loans
Credit Union Memberships and General Powers
The Recording of a Transfer or Assignment of a Mortgage Interest
The Purchase of Flood Insurance
Expedited Judicial Process for Abandoned Properties in Foreclosure
Interest Payable on a Delayed Legacy

2014 Testimony (State and Local)

Bank Tax Reform

2014 Comment Letters (Federal) 

FHFA Proposal on Federal Home Loan Bank Membership
Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring

2013 Comment Letters (State and Local) 

Section 6-m of the Banking Law
Cyber Security
Debt Collection
Membership Qualifications for State Credit Unions
Credit Unions and Deposit of State Funds
Refusal to Disburse Moneys – Financial Exploitation of a Vulnerable Adult
Notice of Contact Information of a Plaintiff in a Mortgage Foreclosure Action
Number of Withdrawal Transactions from a Basic Banking Account
Residential Foreclosure Actions
Debt Collection Agencies
Payment  of Interest on Delayed Legacies
Private Right of Action for Improper Debt Collection
Unsolicited Sending of Blank Checks by Issuers of Credit Cards
Foreclosure Moratorium
Unsolicited Loan Checks
Credit Union Common Bond Expansion
Title to an Abandoned Multiple Dwelling in a City, Town or Village
Civil Practice Law and Rules in Relation to Residential Foreclosure Actions
Notice of Contact Information of a Plaintiff in a Mortgage Foreclosure Action

2013 Comment Letters (Federal)

Credit Risk Retention Proposed Rule
Regarding the Re-Purchasing of Loans
Amendments to 2013 Mortgage Rules under Regulations B, X, and Z
Regarding Mortgage Rules Scheduled to Take Effect in January 2013 

2013 Testimony (State and Local) 

Community Reinvestment Act – December 5, 2013
Statement of Michael P. Smith – New York State Senate – October 8, 2013
New York State Tax Reform Recommendations
Insurance Claim Checks Regarding Storm Sandy

2012 Comment Letters (State and Local) 

Foreclosure Fraud  
Certificate of Merit in Foreclosure Action  
Posting of Contact Info on Foreclosed Property  
Credit Union Membership and Investment Authority Expansion  
Evaluation of Depository Banks (New York City)  
Reciprocal Deposits
Account Inactivity Fee Disclosure 
Banking Development Districts
Land Use Restrictions (New York City)  
High Volume Hydraulic Fracturing
Abandoned Multiple Dwelling

2012 Comment Letters (Federal)

Basel III Capital Proposals
CFPB Streamlining
Interstate Tax Fairness
Federal Home Loan Bank Regulatory Burden
Credit Union Business Lending

2012 Testimony (State and Local)

New York State Assembly: Storm Sandy Checks
New York State Assembly: Financial Exploitation of the Elderly or Dependent Customers
Upper West Side Zoning Restrictions