On October 21, the NYDFS issued new cybersecurity guidance addressing the growing risks associated with regulated entities’ reliance on third-party service providers (TPSPs). The guidance clarifies compliance obligations under the New York Cybersecurity Regulation and outlines best practices for managing cybersecurity risk across the third-party relationship lifecycle.Continue Reading NYDFS Issues Cybersecurity Guidance on Third-Party Service Provider Risk
On September 17, the New York Department of Financial Services (NYDFS) issued a notice advising all state-chartered banks, credit unions, and foreign bank branches licensed in New York to consider integrating blockchain analytics into their compliance and risk frameworks when engaging in virtual currency-related activity. The notice builds on the Department’s 2022 blockchain analytics guidance for virtual currency licensees and its prior requirement that banks seek approval before launching new or significantly different virtual currency activities.Continue Reading NYDFS Directs Banks to Incorporate Blockchain Analytics Into Virtual Currency Risk Programs
On July 28, The New York City Department of Consumer and Worker Protection (DCWP) announced that its amended debt-collection rule, scheduled to take effect on October 1, 2025, has been postponed, leaving the industry in limbo for the third time since the rules were finalized in August 2024. DCWP will set a new effective date with at least three months’ advance notice.Continue Reading New York City Pushes Back Compliance Date of Amended Debt-Collection Rules
On July 9, the New York Department of Financial Services (NYDFS), joined by regulators from five other states, entered into a multistate settlement with a money transmitter headquartered in New York. The $4.2 million consent order resolves allegations arising from a multistate examination conducted by the Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA) citing alleged violations of the Bank Secrecy Act (BSA), FinCEN regulations, and the CFPB’s Remittance Transfer Rule.Continue Reading NYDFS and Other State Regulators Impose $4.2 Million Penalty on Money Transmitter
On June 9, 2025, New York City Comptroller Brad Lander released a report urging City and State leaders to modernize consumer financial protections. The report outlines a series of legislative and regulatory recommendations aimed at closing gaps in existing protections and addressing emerging risks in the consumer financial marketplace.Continue Reading NYC Comptroller Report Calls for Overhaul of State Consumer Financial Protections
On June 13, Judge Katherine Polk Failla of the U.S. District Court for the Southern District of New York entered a stipulated final judgement resolving claims brought by the New York Attorney General against a global money transmitter. The lawsuit, initially filed in partnership with the CFPB (previously discussed here), alleged violations of the Electronic Fund Transfer Act (EFTA), including the Remittance Rule under Regulation E, as well as the Consumer Financial Protection Act (CFPA).Continue Reading New York AG Secures $250,000 Settlement With Money Transmitter Over Remittance Rule Violations
On May 9, the NYDFS announced that Governor Kathy Hochul signed New York’s FY2026 Budget into law, enacting two major consumer financial protection measures. The budget establishes a licensing and supervision framework for Buy Now Pay Later (BNPL) lenders operating in New York and supports NYDFS’s January 2025 proposal to cap overdraft fees and prohibit certain high-cost practices (previously discussed here). Key provisions of the budget include:Continue Reading New York Enacts BNPL and Overdraft Fee Restrictions
On April 14, New York Attorney General Letitia James announced two separate lawsuits against earned wage access providers—one against a company that issues advances directly to consumers, and another targeting a provider that operates through employer partnerships. Both actions allege that the companies engaged in illegal payday lending schemes, charging fees and tips that resulted in annual percentage rates (APRs) far in excess of New York’s civil and criminal usury caps.Continue Reading New York AG Sues Earned Wage Access Companies for Allegedly Unlawful Lending Practices
On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by the Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA). The regulators alleged that the company violated state money transmission laws by failing to satisfy outstanding transmission liabilities, maintain adequate net worth and permissible investments, and continue licensed operations in a financially sound manner.Continue Reading NYDFS Joins Multistate Action Against Money Transmitter for Financial and Licensing Violations
On March 13, New York Attorney General Letitia James announced the introduction of the Fostering Affordability and Integrity through Reasonable Business Practices Act (FAIR Business Practices Act). The proposed legislation seeks to extend the state’s existing ban on deceptive business practices to also prohibit unfair and abusive practices, aligning New York with 42 other states. Continue Reading New York Attorney General Proposes Bill to Expand Consumer Protection Law
On January 22, New York Attorney General Letitia James announced a $1 billion settlement with a now defunct cash advance firm and its officers. The settlement resolves allegations that the firm and its officers repeatedly engaged in fraudulent and deceptive predatory lending practices aimed at small business owners in violation of New York law. Continue Reading New York AG Reaches $1 Billion Settlement with ‘Predatory’ Lender