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MBAofNY is committed to tackling Legislative and Regulatory Issues affecting the industry. We advocate for our members' needs and to build a stronger industry. The legislative committee wants your input. Contact the MBAofNY Legislative Chairperson to get involved and to make sure our voice is heard.





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MARIA VULLO, Superintendent of Department of Financial Services, has announced that she will leave the Department on February 1, 2019.


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At the quarterly meeting of MBAofNY with the Department of Financial Services representatives, our Advocacy committee was able to highlight and address several industry concerns and issues:

  1. Clarified the requirement for MLOs to comply with the Cyber security regulation as independent covered entities;

  2. Spurred NYSDFS to issue industry letters to all MLOs advising them of their need to claim exemption from the cyber security regulation;

  3.  Discussed further streamlining of application processes for both branch applications, banker applications and MLO applications to allow for more efficiencies and cost effectiveness;

  4.  Reviewed examination processes and requested additional guidance so that entities can attain and maintain exam readiness;

  5.  Asked for written guidance for cyber security component of examinations;

Stay tuned as DFS continues to make changes to the Regulations including but not limited to High Cost issues, reverse mortgage issues, etc.


Your Legislative and Advocacy committee continues to meet in district with State and Federal legislators to promote industry awareness.


If you would like to be involved on this committee, please contact us.   Industry needs to promote industry!







The 2016 Volume of Operations Report (VOOR) filing information will be available shortly on the NYSDFS website.  Watch your mail for your log-in information and make sure you file on-time.  Since the data requirements are the same as last year’s VOOR, you may want to get a head start on completing the information in anticipation of filing.  At this time, we do not know if the annual filing date will be extended.


CFPB has issued proposed amendments to the TRID Rule.

The Bureau of Consumer Financial Protection (Bureau) is proposing various amendments to Federal mortgage disclosure requirements under the Real Estate Settlement Procedures Act and the Truth in Lending Act that are implemented in Regulation Z.  The proposed amendments memorialize the Bureau’s informal guidance on various issues and include clarifications and technical amendments.  The Bureau is also proposing tolerance provisions for the total of payments, an adjustment to a partial exemption mainly affecting housing finance agencies and nonprofits, extension of coverage the integrated disclosure requirements to all cooperative units, and guidance on sharing the disclosures with various parties involved in the mortgage origination process.

The comment period ends October 16, 2016. 

 You can read the proposed rule at







6/2/16 -

Please contact your State Senator and urge him/her to vote "No" to S4781. The "Abandoned Property Neighborhood Relief Act of 2016" imposes a duty on the mortgagee or its loan servicing agent to maintain property secured by delinquent mortgage.

Last week the New York State Assembly passed A6932 by a wide margin, and it appears that the Senate companion bill, S4781, is gaining momentum. Lenders doing business in the state of New York should be very concerned about this legislation. If passed, the bill would require lenders/servicers to maintain properties once they are vacant and abandoned, regardless of the fact that the lender/servicer has no ownership in the property and is in store for a foreclosure process that will take at least 3 years. The fine for noncompliance will be $1,000 per day. It is very probable that many lenders will leave the state, due to the legal risk and financial burden that will be placed on them when properties become vacant and abandoned.



4-29-2016  FFIEC announcement regarding the updated examination procedures.

Today the FFIEC has issued a proposal which seeks to update the rating system employed on institutions when examined.  This Consumer Compliance Rating System update will focus on financial institutions compliance management systems, risk assessment and mitigation and internal controls.

There is a sixty (60) day comment period on this proposal.  We will be reviewing the proposal and submitting comments on behalf of Association. We encourage you to review the proposal and submit your comments to the FFIEC and/or the Association for inclusion in its comments to the FFIEC.

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4-26-2016 -  MBAofNY supports elimination of reinsurance requirement mortgage guarantee insurance companies in NY.  MBAofNY continues its work with industry leaders including mortgage insurance companies to ensure New York consumers have access to relevant and affordable financial products and options.

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4-28-16 -  MBAofNY at work for you -
  MBAofNY at work for you: TRID Clarification on Its Way
Click to read -
CFPB TRID Rule Announcement 

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