In January 2026, the New York State Department of Financial Services (“DFS”) adopted its regulations (the “Regulations”) implementing the provisions of the state’s Community Reinvestment Act covering non-bank, independent mortgage bankers, also known as independent mortgage bankers, licensed under the New York Licensed Mortgage Bankers Law (“Mortgage Bankers”). Because the federal Community Reinvestment Act only applies to insured depository institutions, some states, including Illinois, Massachusetts, and New York, have adopted similar laws and applied those laws to non-depository mortgage companies. The Regulations impose filing, self-testing, and self-assessment requirements on Mortgage Bankers; require DFS to evaluate Mortgage Bankers, including by testing their performance in meeting community credit needs; and implicate applications. The evaluation requirements are similar to those imposed on insured depository institutions under the federal Community Reinvestment Act and its implementing regulations.

While the Regulations became effective the same day of their publication—January 7, 2026—the compliance date is July 7, 2026.