On April 22, 2026, the New York State Department of Financial Services (DFS) issued an industry letter reminding entities regulated under the New York Banking Law of their obligations under New York Executive Law Section 296-a, the state's fair lending law. DFS emphasized that it has the authority to enforce state fair lending laws and to impose penalties for violations of federal fair lending requirements.
DFS reminded regulated entities that credit decisions resulting in a disparate impact may constitute unlawful discrimination under Section 296-a. The law prohibits discrimination in the granting, withholding, extending, renewing, or pricing of credit based on protected characteristics, including race, color, national origin, citizenship or immigration status, age, sex, disability, marital status, familial status, sexual orientation, gender identity or expression, military status, and other protected categories. DFS noted that the industry letter does not create new requirements but serves as a reminder that regulated entities must comply with all applicable New York State fair lending laws.
Read the DFS’ letter here.