Posts filed under ‘Advocacy’

Key Federal and State Proposals Rolled Out

Well, the holiday season is officially over. Judging by the amount of information I want to give you in today’s blog, it’s clear that our policymakers are hitting the ground running. Remember, this is an election year.

Let’s start with some federal guidance.

The NCUA released its annual list of supervisory priorities. Close your eyes and guess what NCUA has listed on their agenda for this year. You got it. The BSA compliance! Listen, I understand that few statutes are as important to properly implement, but if there is a credit union out there that doesn’t understand the importance of BSA and have a grasp of how to comply with it, that credit union has issues that a regulatory guidance can’t help with. What I am surprised by is that Libor is so far down on the list. If I were making the list, my top priorities would be cybersecurity, business continuity, which should be viewed as opposite sides of the same coin, potential liquidity risks- because the ongoing need of the Fed to prop up overnight lending facilities continues to scare the bejeebies out of me, and our good friend CECL, because I don’t think credit unions should in any way be encouraged to ignore implementation issues before it’s too late.

As painful as this is for me to admit, as between my priorities and NCUA’s, it makes sense to follow NCUA’s list.

Supervisory Guidance Issued

A regulation which has flown under the radar has been one finalized by NCUA in September intended to assist credit union supervisory committee audits by providing a more concise framework and explanation for minimum audit requirements. Yesterday, the NCUA issued a guidance complimenting this regulation, which succinctly explains what these minimum obligations are. Anyone involved with the supervisory committee should take a look. I of course have some opinions about this as well, but I still have much to talk about today, and I’m in too good of a mood to get hate mail.

Governor Unveils Ambitious List of Financial Services Initiatives

I’m going to go out on a limb here and say that the Governor’s 10th list of legislative priorities for this year’s New York session includes the most comprehensive list of priorities that could impact credit union operations since he was first elected. In addition to the issues he addressed in his State of the State, which included a pointed criticism of banks for not providing services in many of the areas that need them most, his book includes several priorities which we will be scrutinizing once they take legislative form. Among the proposals that caught our eye is one dealing with reporting suspected elder abuse; further strengthening of state law banning unfair and deceptive practices; a state-level crackdown on robo-calls; and enhancing the oversight powers of the Department of Financial Services.

In addition to the issues directly dealing with financial service issues, Cuomo once again called for the legalization of the sale of marijuana for recreational use and even wants to create an institute for the study of hemp and marijuana within the SUNY system. I was chatting with a longtime colleague and lobbyist after the presentation, and he pointed out that one of the reasons you may actually see agreement on this measure is the State’s fiscal deficit. The reality is that the state can plug in estimates of projected tax revenue to help fill the gap.

Believe it or not, there’s even more, but I think you have better things to do with your time than engage in a one-sided conversation with yours truly. That being said, as many of you already know, you can always e-mail me or give me a call if you want to follow up with anything I’ve mentioned.

Have a great day.

January 9, 2020 at 9:36 am Leave a comment

Financial Issues Loom as a New Legislative Session Begins

Good morning!

This is actually one of my favorite days of the year. It is a cross between the first day of school and the first day of spring training for Met fans. So many possibilities, so much hope… so much room for disappointment.

The Governor gives his annual State of the State address today, and given the amount of information that has already been leaked about the presentation, it’s fair to say that financial empowerment is going to be a prominent theme in 2020. Most notably, it appears that Governor Cuomo is going to propose funding the state level CDFI fund. To put this in perspective, more than a decade ago, the legislature enacted a legal framework for a state-level fund to aid in community development financial institutions. Significantly, several credit unions in New York State are CDFIs, but the designation is not limited to traditional financial institutions.

Ever since the framework was created, however, the fund has been nothing more than an outline as it has never actually received funding. Frankly, I have never understood why this is the case, since I’ve never met anyone who opposes the idea. Now, it appears that the Governor’s high level of support at the start of the budget season may actually bring about some action, with $25 million being committed to the fund over a five year period. It is a start.

The Governor’s initiative is part of an effort to “increase access to safe, affordable bank accounts and small-dollar loans in underserved low-income communities across the State.”

Again, this is opening day. We won’t know until the press release gets translated into legislative proposals precisely what will be undertaken or its impact on credit unions.

Meet the New Boss

This is always the time of year when committee memberships get shifted around. One change worth noting is the announcement that Assemblyman Thomas Abinanti of the Westchester area will be the new Banks Chair. He replaces Assemblyman Ken Zebrowski, who has sponsored our municipal deposit legislation in the past. We will of course be reaching out to Assemblyman Zebrowski to discuss the Association’s priorities.

…Speaking of new bosses, Central New York Assemblyman Will Barclay has been named the new leader of the Assembly Republican Conference. The position has waned in recent years as the Assembly is comprised of just 42 Republicans, giving the Assembly Democrats the ability to override vetoes without Republican support. Still, the Minority Leader has a high-profile bully pulpit. In addition, Republicans can delay passage of bills by forcing debate on proposed legislation. In the past, the Assemblyman has been a sharp critic of credit unions.

January 8, 2020 at 9:05 am Leave a comment

Why passage of BDD legislation is a big deal

Good morning folks! As many of you undoubtedly know by now, last Thursday, Governor Cuomo approved legislation permitting credit unions to participate in the Banking Development District (BDD) Program. Here are some initial takeaways.

  • Now comes the hard part. Now that credit unions have the ability to participate in the program, it is incumbent on the industry to take advantage of this opportunity. Here is a link to information about the BDD Program. The Association is, of course, more than willing to help with the process.
  • A win is a win is a win. If the definition of insanity is doing the same thing over and over again and expecting different results, then many credit union lobbyists are pretty close to insane. The BDD Program began in 1996 and credit unions have been arguing for inclusion ever since.   However, persistence gets results and ultimately, the better argument wins the day, even in Albany. It just takes a while.
  • Passage of this bill is an important step toward allowing all municipalities to put deposits in credit unions. Its enactment further undermines the argument that credit unions can’t be trusted with public funds or somehow don’t deserve to play on the same field as banks.
  • Last but not least, this is an important win for New York consumers. Governor Cuomo’s Department of Financial Services originally proposed extending the BDD program to credit unions a few years ago out of frustration that not enough banks were participating in the program. It also recognized that maximizing the number of potential financial partners for local communities in need of economic development was a good thing for New York consumers. The Department was right to propose the bill and the need for struggling communities to access financial partnerships has, if anything, increased in the last few years.

Another big win for CU Field of Membership Case

Credit unions got one step closer to solidifying the decision of the Court of Appeals for the DC Circuit upholding most of NCUA’s 2016 Field of Membership regulations when that same court on Thursday rejected a motion by the bankers requesting that the entire court reconsider the decision en banc. En banc is a motion requesting that an entire circuit court, and not just a three judge panel, reconsider a decision.

The rejection of this motion means that the bankers now must decide whether or not to request that the Supreme Court hear an appeal of a case. My guess is that they will file a petition. After all, if it’s fourth and ten with two minutes left on the clock and your team is down by three points, there is no down side to going for a first down. Also left to be decided is that portion of the decision requiring the NCUA to amend its regulations to prevent racial gerrymandering of credit union service areas.

On that note, have a great Monday!

December 16, 2019 at 7:54 am 1 comment

It’s Congress, Not the Tax Exemption, That is Killing Community Banks

Cachet Financial Services, the company that I talked about in my blog this past Thursday, is going out of business. Cachet is the company that facilitated ACH payroll transactions for MyPayrollHR, whose founder has admitted to engaging in fraudulent transactions totaling in the multi-millions. In my blog on Thursday, I described the relationship that led to tens of thousands of employees not having immediate access to their paychecks. In today’s blog, I’m going to point out how the troubles of Pioneer Savings Bank underscore just how counterproductive and intellectually dishonest the attacks on credit unions by community banks like Pioneer are.

Pioneer has been caught in the MyPayroll mess. It stands to lose at least $35 million because of banking services it provided to the payroll processing company. Pioneer is based in the Albany Capital Region and in January of this year, it reorganized into a mutual holding company. More and more “community” banks have reorganized into these structures. As explained in my trusty Banking Law Handbook, the MHC structure is designed to permit the advantages of being in a holding company structure, which allows the banks to issue stock and gain other access to the capital markets while providing them protection against the ever-present threat of a takeover. The problems faced by Pioneer are serious enough that it felt the need to refile its SEC disclosures, leading to an announcement that it was in danger of being delisted by NASDAQ.

As I explained in my previous blog, my purpose has always been to aid credit unions without bashing banks. It’s extremely difficult to hold my fire in this case, though, because Pioneer has been one of the banks in New York quickest to criticize credit unions and oppose common sense innovations such as permitting credit unions to compete for municipal deposits, in part on the grounds that credit unions are not sophisticated enough to take on these responsibilities. I’m not going to take this opportunity to argue that because of Pioneer’s troubles, no savings bank should be allowed to take on huge commercial loans or accept municipal deposits. It would be dumb to suggest that the mistakes of one or two institutions should be held against an entire industry. Then again, that’s the type of nonsense that the banks argue on both the state and the federal level every day.

In fact, there is much that credit unions and banks could agree on, if only the banks would look at the facts. Most importantly, the consolidation of the banking industry with the resulting demise of the true community bank has nothing to do with the fact that credit unions don’t pay taxes, and everything to do with the deregulation of banking, which has been gradually progressing for decades, but put on overdrive during the Clinton Administration. This has placed tremendous pressure on traditional community banks such as Pioneer to expand into regional entities, or risk being merged out of existence. Most notably, with the passage of the Regal Neale Act, community banks lost the ability to hold their own in specific states. It is not credit unions that have triggered the ensuing merger mania, but the resulting dynamics that this race to get bigger has unleashed.

Banks have always disliked credit unions, and if they could make them disappear, they gladly would. However, it was just a generation ago that the primary focus of community banks wasn’t on destroying the credit union industry, but on ensuring that the federal regulatory framework left space for both small and larger financial institutions. Unfortunately, that has fundamentally changed, and much of the extra zest with which community banks such as Pioneer and bankers associations attack credit unions on these days reflects the fact that they have largely lost the ability to shield themselves against their larger banking competitors. As explained in this phenomenal law review article, “today it is a relatively small group of large diversified financial companies, rather than the far more numerous group of small and community banks, that plays the critical role in shaping the regulatory and legislative dynamics in the financial services sector.”[1]

[1] Saule T. Omarova & Margaret E. Tahyar, That Which We Call A Bank: Revisiting the History of Bank Holding Company Regulation in the United States, 31 Rev. Banking & Fin. L. 113, 196–97 (2011)


October 28, 2019 at 9:24 am Leave a comment


That is how a trusted colleague of mine responded to this article in the CU Times reporting that veteran Congresswoman Carolyn Maloney, who sits on the House Financial Services Committee called for a moratorium on taxi medallion foreclosures during a committee hearing dedicated to debt collection practices. In addition, none other than Rep. Alexandria Ocasio-Cortez referred to some of the taxi medallion loans as “criminal.”

These comments are the latest sign that the taxi medallion issue is not going to go away anytime soon. As policymakers discuss how best to aid drivers in financial straits, let’s hope that some basic facts are understood. Most importantly, the medallion crisis cannot be separated from the rise of Uber and Lyft. We would not be having this discussion today if these two companies did not upend the entire structure of the taxi industry and destroy the value of medallions.

In addition, many medallion loans are now being serviced directly by NCUA. NCUA has to do more to publicly explain to policymakers on both the state and federal level what steps it is taking to modify these loans. Many credit unions are working with members, but that message is not getting out to the public as effectively as it should be with NCUA in control of so many of the lending decisions.

Finally, I hope legislators think long and hard before advocating for a foreclosure moratorium. The reality is that the price of medallions has tumbled and may very well continue to do so. A moratorium would do nothing except put further downward pressure on medallion prices, and extend the time it will take to get the medallion crisis behind both drivers and lenders alike. Instead of talking about moratoriums, policymakers should look at the example of the HAMP Program and see if there are mechanisms to assist both lenders and borrowers in making financially responsible modifications. Stay tuned.

A Phase-in for CECL

In addition to a delay in its effective date, another piece of good news on the CECL front is that Chairman Hood has indicated that NCUA will be joining with banking regulators in permitting credit unions to phase in recognition of loan losses triggered by the new standards over a three-year period.

CECL requires financial institutions to recognize lifetime expected credit losses, and not just credit losses incurred as of a reporting date. In addition, it implements a lower threshold for financial institutions to recognize a potential credit loss. As a result, many institutions could experience a reduction in their retained earnings as they increase buffers to guard against potential losses.

Many banks and credit unions have expressed concern that they could face dramatic losses on paper if they are not allowed to phase in the recognition of losses caused by this new standard. Earlier this year, the OCC and FDIC finalized regulations giving banking organizations that experienced a reduction in retained earnings as a result of adopting CECL the option of phasing in its effects over a three-year period. At a presentation before NAFCU earlier this month, Chairman Hood indicated that NCUA will be proposing similar regulations for credit unions.


September 27, 2019 at 9:51 am Leave a comment

Washington Tees Off On Facebook; Senate to Hear from CU’s on Pot Banking and Main Street is where the $ is

Today is the last day of the blog until I return from a week’s vacation on July 29th. Here is some info I wanted to make sure you knew before I head to Cape Cod this weekend.

Facebook cemented its status as the latest company everybody loves to hate. The US Senate Banking Committee held a hearing yesterday Scrutinizing Facebook’s plans to introduce a block chain cryptocurrency for Consumers sometime next year. As expected. reactions to the plan ranged  from polite skeptical to hysterical.

In the polite skepticism category is this quote in the American Banker from committee chairman Mike Crapo “Despite the uncertainties, Facebook’s stated goals for the payments systems are commendable,” Crapo said. “If done right, Facebook’s efforts to leverage existing and evolving technology and make innovative improvements to traditional and nontraditional payments systems could deliver material benefits, such as expanding access to the financial system for the underbanked, and providing cheaper and faster payments.”

In the hysterical category is this quote from the committee’s ranking senator, Democrat Sherwood Brown: “Facebook is asking people to trust them with their hard-earned paychecks,” said Brown. “It takes a breathtaking amount of arrogance to look at that track record and think, you know what we really ought to do next? Let’s run our own bank and our own for-profit version of the Federal Reserve for the world.”

With all due respect to the senator, a company started in 2004 as a dorm room platform to categorize coeds that grew into the world’s dominant communication platform is entitled to a little breathtaking arrogance. Besides, this country has been breathtakingly slow and arrogant to adopt payment system Innovations. It’s time to give the private sector a turn. The sky is not going to fall. It isn’t time to start the campfire with dollar bills

Upcoming hearing on Cannabis Banking

Speaking of the Senate Banking Committee, it will be holding a cannabis banking hearing on July 23rd and the concerns of credit unions will be front-and-center.

Rachel Pross, the chief risk officer of Maps Credit Union in Oregon,  is scheduled to be the lead speaker on the committee’s second panel following comments by senators Gardner and Merkley, both of whom represent States that have legalized cannabis.

The Credit Union has been on the cutting edge of providing banking services to marijuana businesses. In testimony before a House committee earlier this year Pross explained that the credit union has been providing these services since 2014 when Oregon voted in a referendum to legalize cannabis.

The conventional wisdom is that the House has the votes to pass legislation permitting  states which have legalized marijuana, to continue to do so without violating federal law but it will take a much bigger lift to get this done  in the Senate.

 Consumer Banking Heats up as Investment Banking Cools

The all-important earnings season, when publically traded company’s announce and put their best spin on their quarterly earnings is here. If current trends continue expect the big guys to continue to move aggressively to expand their consumer banking presence.

There is no better bellwether for the state of U.S. banking than JPMorgan Chase so here is a link to information about it second quarter earnings report. Page 3 of the press release demonstrates that  the behemoths are growing by capitalizing on consumer banking. The WSJ points out this morning that while the American consumer is generally in a good mood businesses which generate money for investment are much less sanguine about the economic outlook. Expect to face even more competition.



July 17, 2019 at 10:06 am Leave a comment

Previewing What Promises To Be A Wacky Week

To understand the New York State legislature in the closing week-and-a-half of the legislative session, you should think back to your school days. Deadlines which seemed to be in the distant future suddenly arrive and all that work you swore you had already done needs a lot of fine tuning. Get ready for the late nights.

So it goes for the legislative session this week as the legislature continues to consider a wide variety of bills that could impact your credit union operations. I will try to keep you posted as things unfold.

One of the bills I’ll be keeping an eye on, which has gotten the attention of the New York Law Journal, would effectively reverse regulations promulgated by the Department of Financial Services placing strict new limits on the marketing activities of title insurers in the Empire State.

Another reason this promises to be a wacky week is that economists, politicians, Presidents, candidates and talking heads of all political persuasions will continue to extrapolate prognostications about the future of the economy. If the economy does end up slipping into recession marking an end to one of the longest economic expansions in history then Friday’s job report in which an underwhelming 75,000 new jobs were created will be seen as a key moment.

Similarly, we have seen a dramatic decrease in bond yields as investors run for the safer cover of bonds. It will be interesting to see where and when this trend ends. It will also be interesting to see if and when quickly the fed decides that it needs to cut interest rates. Obviously all of this has an impact on your net interest margins.

This week will also give us more time to analyze how best to regulate payday lending. On Thursday the CFPB took the unusual step of providing a red line version of its regulations while announcing that it was delaying the date by which lenders had to comply with payday lending regulations.

I am also curious to find out if the FCC faces additional pushback now that it has rushed through regulations making it easier for telephone companies to block “robocalls.” I put robocalls in quotes because no one really knows what exactly will be blocked now that this regulation has been promulgated. This article in the WSJ summarizes the frustration that so many of us feel when trying to explain to people why the FCC’s action makes no sense. “America’s telecommunications regulator passed rules last week that will let phone companies automatically block more robocalls. It hasn’t yet said what, exactly, constitutes such a call.” That’s right. The regulation actually doesn’t ban robocalls. It bans calls made with equipment that can make robocalls.

This has the look and feel of a regulation that needs to be challenged on the grounds that the regulators have violated the Administrative Procedures Act. Perhaps we will see that happen this week as well.

June 10, 2019 at 9:16 am Leave a comment

D-Day For Robocalls?

I found myself yelling at my radio this morning as either NPR or Bloomberg was reporting that the FCC was poised to take final action today on a proposal to make it easier to block robocalls.

I was yelling at the broadcast because the proposal does much more than that. I might be able to live with the regulation if we could come up with a legitimate definition of what a robocall is but alas, the definition is dependent not on the nature of the communication but on the type of equipment used to make the robocall.

Second, by giving telephone service providers the authority to block all the member’s unwanted calls unless they opt in to receiving them, the proposal raises a host of compliance conundrums. For example, by the end of the day today you may very well find it more difficult to reach out to delinquent homeowners who the CFPB says you have to discuss loss mitigation options with. And what’s going to happen when there is a conflict between the documented approval you have received to contact members and the fact that the member has not affirmatively opted in to receiving electronic communications.

By the way, the FCC is taking these steps notwithstanding some great work by CUNA and the industry. As this article report from Fox Business makes clear CUNA was able to place itself in the forefront of these legitimate concerns notwithstanding the great next speed at which the FCC is determined to jam this regulation through. Stay tuned.

The Chase Is On

The Albany Business Review is reporting that Chase plans to open several new branches in the Albany Metropolitan area marking its first aggressive push into the market. The Review notes that the move reflects a broader strategy on the part of the bank to both consolidate branches and concentrate on growing in the major metropolitan areas.

BDD Bill Advances

Finally some good news to report this morning. The efforts of credit unions to become eligible for participation in the state’s banking development district program took an important step forward yesterday when the legislation was voted out of the Bank’s Committee. It now goes on to Ways and Means. We will keep you posted on future developments.

June 6, 2019 at 9:02 am 2 comments

Facebook Has A New Pen Pal: The Senate Banks Committee

On Friday, the Chairman and Ranking Member of the Senate Banks Committee sent a politely worded letter to Facebook inquiring about its plans to move aggressively into the payments market by offering its users the opportunity to buy products directly from merchants using a Facebook backed coin or cryptocurrency depending on how nefarious you want to make its plans sound.

Why is this a big deal? Well how much money do you make off credit and debit card transactions issued by your credit union? If Facebook successfully integrates the coin payment platform into its infrastructure this would mean that 1/3 of the world’s population could start using Facebook to facilitate purchases, making Facebook an overnight threat to Visa and MasterCard.

In their letter to Facebook, following an article describing Facebook’s plans in the Wall Street Journal, the Senators explain that in addition to Facebook’s cryptocurrency ambitions, “privacy experts have raised questions about Facebook’s extensive data collection practices and whether any of the data collected by Facebook is being used for purposes that do or should subject Facebook to the Fair Credit Reporting Act.”

As with so many other aspects of its growth Facebook is somewhat clumsily taking aim at the financial sector. In addition to questions about its cyber currency ambitions, it is currently being sued by HUD over claims that it violates its advertising platform allows lenders to effectively engage in digital redlining by choosing such finely tuned demographic target audiences in such a way that lenders can avoid offering financial products and services to minorities.

Assembly To Hold Municipal Deposit Hearing Next Monday

In case you haven’t heard, the Assembly Banks and Local Governments committee will be holding a hearing on municipal deposits next Monday. An assortment of credit union, bank and local government organizations have been invited to testify. This is a key opportunity for credit unions to respond to banker municipal deposit myths and finally allow public tax dollars to be placed in those financial institutions where they will most benefit taxpayers.

Department of Treasury Issues OFAC Guidance

I’ve been analyzing this guidance for a couple weeks now trying to figure out how significant it is and why it was issued in the first place. It seems to me that nothing in this release should be a surprise to anyone who has tried to comply with OFAC which I’m assuming almost all of my faithful readers have. Nevertheless, any time the Department of Treasury comes out with guidance on this issue you should read it and compare your practices with those expected by the regulator.

May 13, 2019 at 8:45 am Leave a comment

If You Call Your Members, This Case May Impact You

There is an important case pending before the Court of Appeals for the 11th Circuit which will have a direct operational impact on the type of technology your members can use to reach out to potential members. It also underscores just how unhinged the TCPA has become from Congress’ original intent and why Congress should do something to restore commonsense.

First, a primer/refresher on the issue I am talking about. The Telephone Communications Protection Act (TCPA) was passed in 1991. Its Senate sponsor, Senator Ernest Hollings of South Carolina who passed away recently, described the emerging use of automated telemarketing campaigns as “the scourge of modern civilization. They wake you up in the morning, they interrupt our dinner at night, they force the sick and elderly out of bed; they hound us until we want to rip the telephone out of the wall.” While the Senator may have slightly overstated the case, the reality is many consumers continue to feel harassed by these non-stop calls and their frustration has made TCPA litigation one of the hottest areas of consumer class-action lawsuits. Credit unions have not been exempt from this trend.

The legislation he sponsored was codified as 47 USC §227. This law makes it unlawful for any person to make any call other than for emergency purposes using “any automatic telephone dialing system or an artificial prerecorded voice unless the person has an established business relationship with the recipient.” Seems simple enough except the statute defines an Automatic Telephone Dialing System (ATDS) as equipment “which has the capacity–(A) to store or produce telephone numbers to be called, using a random or sequential number generator; and (B) to dial such numbers.”

Melanie Glasser was upset enough by her marketing phone calls from Hilton that she agreed to be the named plaintiff in what she hopes will become a class-action lawsuit. Glasser v. Hilton Grand Vacations Co., LLC., 341 F. Supp. 3d 1305, 1306 (M.D. Fla. 2018), This case does not deal with whether or not she gave Hilton consent to call her. Instead it centers on the type of equipment the company used when it made the allegedly offending phone calls. The company openly admits to using a new computerized telephone calling system specifically designed to comply with the TCPA in a way that allowed it to automate much of the calling process. Its Intelligent Global Connect dialing system uses software to determine who is going to get called but requires an employee to press a button before each call is completed. The plaintiff argues that this is a distinction without a difference but the case was dismissed by the federal district court. It concluded that because “human intervention is necessary for the numbers to be dialed, the equipment and consequently the calls being made is not covered by the TCPA.” The case is now up on appeal and the briefs read more like patent applications than an examination of appropriate marketing practices.

Although this case is only binding in the 11th Circuit,  If this ruling is upheld it will give businesses including credit unions clear-cut guidance as to what type of equipment does and does not comply with the TCPA.

It is also another great example of why all sides need to come back to the table and fix this out-of-control statute once and for all. Personally, I feel that the goal of the statute is worthwhile. People shouldn’t be inundated with unsolicited offers for things they don’t want. The problem is that, as drafted, the trigger for TCPA compliance is the equipment being used and not how it is being used. As a result, almost all businesses including all but the smallest of credit unions either use or will be using equipment that makes them subject to the TCPA even if they never use that equipment for the type of mass marketing, computer generated automated calls the statute was designed to prevent.

We also need some more commonsense guidance as to what constitutes consent but I’ve run out of space for today’s blog.

April 11, 2019 at 9:19 am Leave a comment

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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.

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