Posted By: Cloud9
418 and 419 - 03/18/20 06:38 PM
I have no experience with New York law and have just become aware of these. Are national banks exempt? Are the requirements the same as RESPA and Regulation Z? I also saw mention of an effective date of 3/17/2020 on some part, can you tell me what that is? Can anyone please help or head me in the right direction? Thank you!
Posted By: Soccer
Re: 418 and 419 - 03/20/20 01:00 PM
Cloud 9,
Section 418 & 419 are strictly regulated by NYSDFS. I am a state chartered bank so I have to abide by them. As a national bank I believe you are exempt.
Posted By: edAudit
Re: 418 and 419 - 03/26/20 08:45 PM
https://govt.westlaw.com/nycrr/Document/If428f6c27c6511de9ceed42160bedbcb?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)
(a) Exempt organization.
Any insurance company, banking organization, foreign banking corporation licensed by the superintendent or the Comptroller of the Currency to transact business in this State, national bank, Federal savings bank, Federal savings and loan association, Federal credit union, or any bank, trust company, savings bank, savings and loan association, or credit union organized under the laws of any other state, or any instrumentality created by the United States or any state with the power to make mortgage loans.
https://govt.westlaw.com/nycrr/Document/I61aa37a2d23111dfa27ecf558d5ad622?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)
For purposes of this Part, unless otherwise stated herein, terms shall have the same meaning as set forth in Part 418 of this Title.