0000004275 00000 n
0000001849 00000 n
startxref
0000032297 00000 n
In particular, the compliance program should ensure that the business personnel understand their duties and responsibilities under the Plan and that such duties are being carried out; The Plan should implement a training program that provides adequate training to new hires and current employees, including management and other key personnel, and provides lending personnel with at least semiannual updates on fair lending issues. Compliance personnel should administer and conduct the training program and participants should certify that they understand and commit to upholding the principles of Executive Law 296-a and the policies and procedures contained in the Plan; The Plan should provide for an automatic and timely review by a higher level supervisor of all applications that are rejected or withdrawn; The principles of the Plan should extend to the Lender's refinancing and collection practices; The Plan should address how the Lender will disclose and document to an applicant that he meets underwriting standards that typically would qualify him for an alternate loan product and whether that applicant will be referred to an affiliated lender; The Plan should identify actions taken to demonstrate that the Lender has taken the appropriate measures to extend the policies and procedures of the Plan to the solicitation, establishment and maintenance of the institution's relationships with other lenders. 182 36
0000001727 00000 n
0000018292 00000 n
trailer
0000032190 00000 n
xb```b``me`e`Qgg@ ~+
k00L$(n229 PPH@x&L e (u:K|jd[9jU; >[.f {.fzaACg/p{X@ o1
<<2E48481A7FC5874FA504C3F832F9C40D>]>>
0000004610 00000 n The Plan should be periodically reviewed by the Compliance Officer and senior management to ensure that it remains current. It is the responsibility of the Board of Directors and senior management to formulate the Plan and ensure that the lending practices of the Lender comply with its provisions. 0000005114 00000 n xbb``b``3i~0 } Dr;79?q!\\6I_1]]oy[zx8SD2sS]Z. 0000011247 00000 n
Further, even though the Lender's Plan may address all of the areas outlined above, that is no guarantee that the lending activities being conducted by the Lender comply with the provisions of Executive Law 296-a. Risk based pricing is and continues to be valid in New York, provided that it is not impermissibly tied to a protected class. 0000011883 00000 n 0000024079 00000 n Please be advised that implementation of this requirement is not an attempt by the NYSBD to compel Lenders to abandon the use of objective factors in evaluating the creditworthiness of a borrower when determining whether to underwrite a loan. Monitoring should be conducted for the Lender as a whole, as well as sub-parts of the Lender. Peter M. Philbin, endstream endobj 216 0 obj<>/Size 182/Type/XRef>>stream 0000018468 00000 n 182 0 obj <> endobj 0000019819 00000 n 0000003120 00000 n 0 0000002205 00000 n 0000020853 00000 n 0000001035 00000 n 0000010116 00000 n xref As part of our effort to eliminate prohibited practices, the NYSBD requires applicants seeking a license to become a licensed lender or sales finance company ("Lender"), applicants seeking approval for a change of control of a Lender or applicants seeking permission to open an additional branch to submit a satisfactory Fair Lending Plan ("Plan") as part of their application. 0000001526 00000 n Lenders, or their legal counsel, should direct any questions or comments to Alvin A. Narin, Assistant Counsel, at (212) 618-6680. 0000018568 00000 n 0000017919 00000 n 0000021994 00000 n Accessibility & Reasonable Accommodations. %%EOF
- Pyspark Set Driver-memory
- Uf School Of Music Calendar
- Ssl Certificate Without Email Verification
- Best Glow In The Dark Keychain
- Siete Grain Free Churro Strips
- Battle Cats Glitches 2022
- Basics Of Additive Manufacturing
- Fitness Photoshoot At Home
- Neem Oil Vs Captain Jacks Dead Bug
- Ccac Backflow Certification
- Eglobal Creative Publishing Jobs