On November 14, 2016 I signed and sent a letter to DFS Deputy Superintendent Cassandra Lentchner.

In September, the DFS issued a proposed regulation for all "covered entities" under DFS purview, which includes all underwriters and licensed title agents. The regulation, designed for the enormous global financial institutions regulated by DFS, imposed drastic changes to security procedures, compliance, business operations, reporting and company governance.

The general assessment is this regulation is a positive development for both consumer and financial services protection. The specifics of the regulation proved in some instances to be overly burdensome and ill suited for the kind of business title companies conduct.

The letter was the result of more than a month of work by a specially appointed joint working group of volunteers drawn from the Government Regulations Committee and the Technology Committee.  This project was headed by Jean Partridge, who also was the primary author of the document. She was advised and supported by Bill Collins, Victor Pajonas, Chris Davis and Vincent Danzi.

The letter is attached to this blog post and it resides in the Government Regulations File Library, on this web site [RESOURCES>DOCUMENT & FILE LIBRARIES].

The joint working group worked cooperatively with counterparts at FNTG, Old Republic, Stewart Title, First American, and ALTA. There was cross-industry collaboration with trade associations representing property & casualty agents in NY and DC- based financial institution trade associations. As always, our Albany lobbyists, Scott Wexler and Kate Corkery provided advice and perspective.

For a regulation that has the potential for profound impact on title agents - and by profound I mean expensive - the awareness and engagement from the membership was imperceptible.I announced this regulation and posted the proposed in an email blast.  I provided an email address for comments. One member commented. NYSLTA is fortunate to have such skilled and dedicated members, such as the handful of people who produced this letter.

This Association will continue to seek engagement with DFS on your behalf. The challenges ahead are countless. Your contribution of time and your expertise are much needed and always welcome.

RGT