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Keith Salmeri is an Associate and member of Stark & Stark’s Real Estate, Zoning & Land Use, and Banking & Financial Services groups, where he represents developers, landowners, lenders, and individuals in a wide range of matters for the real estate and banking industry, including commercial real estate purchases and sales, leasing, loan transactions, and land development projects.

New York Commercial Finance Disclosure Law | NY State CapitolOn December 23, 2020, then Governor Andrew Cuomo signed into law NY CLS Fin Serv §§ 801-812 (the “Disclosure Law”) with the intended purpose of “requiring certain providers that extend specific terms of commercial financing to a recipient to disclose certain information about the offer to the recipient.” Although the law was slated to take effect January 1, 2022, the New York Department of Financial Services (“DFS”) issued a guidance on December 31, 2021, stating that the “obligations do not arise until the [DFS] issues final implementing regulations and those regulations take effect.” Given the latest regulations proposed by DFS provide for a compliance date six months after publication of the Notice of Adoption in the State Register, companies have until at least the summer of 2022 to comply with the Disclosure Law.

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