SFNet Submits Comments to New York Department of Financial Services Regarding Proposed Financial Disclosures Regulations

As has been previously reported, New York State has enacted financial disclosure legislation affecting lenders (including ABL, Factors and Fintech) who make advances to New York State borrowers of $2,500,000 or less. The most challenging of these disclosures is a requirement that any potential borrower be provided an APR-based metric detailing the “cost” of the lender’s advances prior to the closing of the transaction. New York’s Department of Financial Services issued draft regulations (https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202109211) in September. SFNet has submitted a comment letter and addendum. If you have any questions or comments, please contact Michele Ocejo at mocejo@sfnet.com.