New York Bankers Association

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.

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

nsolicited 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