Effective March 1, 2017, all lenders operating in New York State were notified that they have 180 days to ensure compliance with 23 NYRCC 500, “Cybersecurity Requirements for Financial Services Companies.” These new regulations establish specific safeguards that lenders are expected to adopt, as well as audit, risk assessment, third party service provider oversight, annual reporting and incident reporting rules.
When the CFPB issued its Bulletin 2012-3 addressing third party service provider risk management, the industry largely responded with a blank stare. Because most lenders had never developed risk management protocols and vetting processes for vendors, there was significant confusion about what they needed to do to satisfy regulators.
We now know that our next President will be New York real estate mogul Donald J. Trump. Immediately after the election the industry was buzzing with articles predicting that a Trump Presidency would mean the death knell for the Consumer Financial Protection bureau (CFPB). It will never happen for several reasons.
Never heard of “blockchain” technology? Well then you better start Googling it, because like the fax machine, personal computer and the Internet, blockchain data authentication, storage and sharing technology promises to change the way financial transactions occur in a transformational way. Along the way the way banks make loans, and the way we access public data (including property title information) could be radically changed, many say for the better.