New York Adopts Final Commercial Financing Disclosure Regulations

On February 1, NY DFS announced the adoption of the final regulation implementing the New York State Commercial Finance Disclosure Law (CFDL) (N.Y. Fin. Serv. Law §§ 801 to 812). The regulations require companies that offer commercial financing less than or equal to $2.5 million (providers) to make standardized disclosures about the commercial financing’s credit terms to recipients of the commercial financing (recipients). The final regulations were effective February 1, 2023, and the compliance date for the final regulation is […]

By | May 20, 2024 ||

A Look Inside California’s Commercial Financing Disclosure Regulations

Nancy Thomas and Calvin Funk authored an article for The Banking Law Journal looking at the core disclosure requirements of the regulations recently issued under California’s new commercial financing disclosure law and some of the key issues that providers will need to navigate as they prepare compliance disclosures. “The California Office of Administrative Law has approved the Department of Financial Protection and Innovation’s [DFPI] final regulations implementing California’s first-of-its-kind commercial financing disclosure law,” the authors […]

By | May 18, 2024 ||

US Federal Reserve Proposes Publishing List Of Institutions With A Master Account

On November 4, 2022, the Board of Governors of the Federal Reserve System (Federal Reserve) proposed to periodically publish a list of depository institutions that have access to Federal Reserve accounts—often referred to as “master accounts”—and payment services.1 This proposal would reverse a position that the Federal Reserve adopted in its recent account access guidelines and is intended to bring greater transparency to an arcane area of federal banking law. However, even if the proposal […]

By | May 16, 2024 ||