Dear New York State Department of Financial Services,

Please stay in your lane. P.S. No one likes you or your ideas.

https://risk.cmail19.com/t/ViewEmai...DCF99AA49ED5AF8B9E?alternativeLink=False

I am going to wager that you do not work in NY? The NY DFS wields immense power and many, many banks do not want to run the risk of being in their cross hairs.

ACBbank, you are correct, I'll still live and work in a free state. I keep reading about the nightmares from California and New York banks. I feel for you

Apparently the CFPB does. In recent exams, they're telling state-chartered banks that it's a UDAAP if they don't provide the consumer protections of the most consumer-friendly state in which they operate to all customers, regardless of state.

True! Hopefully with the CFPB getting slapped around about the unconstitutionality of their fund apparatus will help slow down their overreach.

Don't hold your breath. The same court upheld the process they used to adopt the regulation; it was only the funding mechanism that was invalidated. Contrast that with the PHH decision several years ago in which the Court of Appeals invalidated the agency's view of RESPA Section 8, its position on the applicability of the statute of limitations to its enforcement action, and its attempt to "regulate by enforcement." If that didn't slow them down, I'm not sure exactly what it takes.

I am in NY and the need for NY to be "first" is one of the many reasons I will be retiring on June 30, 2023. I've had enough!

Congratulations Soccer. I hope you enjoy retirement immensely.

Thank you, looking forward to it.