GDB Firm Blog
MAY 29, 2019
In all situations, whether the landlord owns one or 1,000 apartments, New York's General Obligations Law requires that security deposits and pre-paid rent be deposited into a segregated account and cannot be deposited into an account which also contains funds from any other source.
GDB Firm Blog
MAY 28, 2019
You remember Department of Financial Services Part 504? When proposed, it threatened criminal prosecution for Transaction Monitoring Program (TMP) violations. We (I drafted the comment letter for the Banking Law Committee of the NYS Bar Association) convinced DFS to remove that threat, but the rule retained teeth that may have bitten Deutsche Bank. The New York Times reports that a senior officer of the bank countermanded a decision to file a SAR on the President's son-in-law.
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