View or download a PDF of the comment here.

Public Citizen and Americans for Financial Reform Education Fund submitted a comment to the New York State Department of Financial Services (DFS) on its proposal to evaluate nonbank mortgage lenders in New York based on their performance in meeting the credit needs of the communities where they operate, including needs related to increasing climate risks on housing such as building physical resilience and preventing bluelining. All mortgage lenders in New York must provide equitable access to credit, particularly to low- and moderate-income (LMI) communities. This proposed rule is an important step in furthering those goals.