NYDFS's New (and Expanded) Servicer Vendor Management Expectations

Originally proposed by the New York Department of Financial Services (NYDFS) in 2019 and constituting what the Mortgage Bankers Association has described as "the first major update to Part 419 since its adoption almost 10 years ago," the new Part 419 of Title 3 of NYDFS regulations covers a range of significant issues impacting the servicing community. These changes include Section 419.11, which imposes significant vendor management expectations on financial services companies servicing borrowers located in the state of New York. With an effective date of June 15, 2020, time is of the essence for servicers to ensure their vendor management programs and processes meet NYDFS expectations.