‘Twas Five Days Before Christmas…

December 20, 2019 at 9:33 am 2 comments

And can you believe that there are some new regulations I still have to tell you about? More and more of us in the industry have noticed that there is increasingly less down time. Personally, I feel this reflects the maturity and sophistication of the industry. Besides, it’s good job security.

First, I want you to know that the Department of Financial Services finalized regulations amending Section 3 NYCRR 419 of New York’s regulations dealing with mortgage servicers. There’s a lot here, but I would scrutinize the change in the definition of affiliated relationships, as well as the expanded definition of settlement services.

…Also for you mortgage gurus, a friendly reminder that before you take the week off, you may want to double check to make sure you are ready to send out the notices required under the Taxpayer First Act. Under this law, persons disclosing taxpayer information to third parties must obtain the taxpayer’s consent. I provided a link to the Fannie Mae update on this issue because this legislation will be most relevant for those of you who originate mortgages and then sell those mortgages to third parties.

…While I’m giving you a heads up, in case you missed it, Senator Crapo of the Banks Committee played Scrooge to those of you with visions of eating organically infused Christmas cookies when he announced that he has serious problems with the SAFE Act. This is the vehicle passed by the House that would essentially allow credit unions and banks to provide banking services to marijuana-related businesses in states that have legalized its sale and distribution. I was naïve enough to think that this was one of those issues on which there could actually be a bipartisan consensus comprised of states’ rights republicans and pro-legalization democrats, but apparently, I was too optimistic. I apologize. This won’t happen again.

In the meantime, remember that this has no impact on the sale and distribution of hemp. By the way, the Association is putting together a workshop on this issue on February 4th. Please take a look at the calendar and sign up if you get a chance, as we’d like to gauge how much interest there is on this subject.

…Finally, I’ve noticed that blogs don’t die; they just fade away, usually because the blogger realizes how much work is involved and simply stops producing one. I am too stubborn to come to that conclusion, so I will be back after my long winter hiatus with another year of tidbits that I hope make your credit union world a little more manageable. In the meantime, merry Christmas, and I would love all you compliance people to take a look at this extremely clever video post recently sent out by Linda Bow, our director of compliance.

On that note, happy holidays, with a special shout out to those of you who are gathering at my house for the first annual Meier family festivus celebration featuring feats of strength and highlighted by when we gather around the table and I explain to all of the lucky participants how they have disappointed me in the previous year. I’ve invited politicians from across the political spectrum as well as some regulators, but they have not yet RSVP’d, which my wife says is extremely rude. I frequently show up at parties without responding to the RSVP.

In all seriousness, thanks for reading, and have a great holiday.


Entry filed under: Compliance, General, Mortgage Lending, New York State, Regulatory. Tags: , , , , , .

CUNA: Scrap the CFPB and Pick Up the Pieces New York State Rings in the New Year With a Host of New Mandates

2 Comments Add your own

  • 1. Mike Carter  |  December 20, 2019 at 10:24 am

    Henry, Happy Holidays to you and yours! I consider myself a faithful reader and am looking forward to the great information, sprinkled with a sufficient amount of sarcasm, in 2020!


Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

Trackback this post  |  Subscribe to the comments via RSS Feed

Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Join 785 other followers


%d bloggers like this: