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.

2021 Comment Letters (State)

Electronic Notarization
Anti-Trust Bill
Credit Card Rewards Programs
"Anti-Engel" Bill
Affirmative Allegations Applicable to All Mortgages
Public Banking
Private Right of Action in Improper Debt Collection
General Jurisdiction of Foreign Corporations
Insurance Insolvency
Credit Unions and Public Deposits
Credit Unions and Excelsior Linked Deposits
Estate Tax Increase
SBA PPP Forgiveness Delays
NYBA and Coalition Opposes Tax Increase
Joint Letter Opposing Stock Transfer Tax
Insurance Insolvency Laws 

2021 Testimony

Electronic & Remote Notarization
NYC Council: Public Banking

2020 Comment Letters (Federal)

Troubled Debt Restructuring Designations
FHFA RFI Comment Letter FHLBank Membership
Troubled Debt Restructuring Designations

2020 Comment Letters (State)

MEMORANDUM IN OPPOSITION AN ACT to amend the banking law, in relation to mortgage forbearance repayment
Notice of Foreclosure to Tenants
Banking Development District Proposals


2019 Comment Letters (Federal)

HUD Disparate Impact Proposed Rule

2019 Comment Letters (State)

Credit Unions and BDD Program
Appraisal Management Companies
Vacant and Abandoned Property

Regarding Student Loan Servicers 
Statement on Budget Hearing and Cannabis Banking
New York State Department of Financial Services’ Proposed Regulation Part 419 “Servicing Mortgage Loans: Business Conduct Rules”
Lack of Standing in a Foreclosure Action

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