NY Proposes Regulation Requirements on Small Business Loans

Wednesday, September 29, 2021

On September 21, 2021, New York’s Department of Financial Services (DFS) announced proposed regulations that clarify the small business Truth in Lending disclosure requirements that go into effect on January 1, 2022. The proposed regulations come just in time as non-banks and fintechs are attempting to prepare to comply with the commercial financing law with limited guidance.

Commercial Financing Law

As we discussed in the past, in late December of 2020, the New York Legislature passed SB5470, which mandates Truth in Lending-like disclosure requirements for commercial financing transactions. On February 16, 2021, former New York Gov. Andrew Cuomo signed into law SB898, which amended the commercial financing law by broadening the scope of the previous legislation and extending the effective date. Initially, the law only applied to…

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