On November 20, 2017, the New York Mortgage Bankers Association and the Mortgage Bankers Association (MBA) submitted joint comments to the New York State Department of Financial Services regarding a Department’s proposed rule, giving them broad enforcement authority over credit reporting agencies. The rule gives the Department the ability to refuse to renew, suspend or revoke the registration of a credit reporting agency, including any of the three nationwide credit reporting agencies. Should the Department take one of these actions against a nationwide CRA, borrowers in New York State would be unable to obtain a tri-merged credit report, a requirement for FHA, VA, USDA, Fannie Mae and Freddie Mac financing. New York borrowers moving to other states would also be impacted. To view the proposed rule and the NYMBA/MBA comments, click on the following links:
PROPOSED RULE
NYMBA/MBA COMMENTS