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 Thus, expanding the Statutes reach. It is worth noting that under New York Usury laws, the charging of interest in excess of 25% on a loan less than $2,500,000.00 is considered criminal usury. Ostensibly now, non-conventional loans under $2.5MM in New York are subject to both SB 5740 and to New York criminal usury. https://grantphillipslaw.com/new-york-mca-laws-updated/

 The new TILA-like Disclosure requirements were signed into law on December 23rd of 2020 with an original commencement date of June 21, 2021. However, since passing S.B. 5470 the New York Senate has provided additional guidance and updates (In March 2021), and included in this update is a new date for commencement of the law to begin January 1st, 2022. https://grantphillipslaw.com/new-york-enacts-apr-disclosure-laws/

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 S.B. 5470 is a New York law requiring non-bank lenders to provide corporate borrowers specific disclosures in the loan paperwork and prior to formal consummation of the loan. The law was enacted in order to create more transparency for small business borrowers surrounding their application for credit from non-conventional banking institutes. https://grantphillipslaw.com/new-york-enacts-apr-disclosure-laws/

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 Perhaps. Time will tell. With the advent of financial technology, providers and lenders of corporate finance have become more sophisticated and continually seek to “invent” new and complex lending structures that bad actors can use to engage in predatory and lending abuses. S.B 5470 seeks to govern these creations and inventions by requiring the disclosures delineated in more detail further into this article. https://grantphillipslaw.com/new-york-enacts-apr-disclosure-laws/

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