Key takeaways

• Maria Vullo, a former corporate attorney who worked in the New York Office of the Attorney General under Andrew Cuomo, has been confirmed as the new Superintendent of the New York Department of Financial Services.
• Given the institutional experience at the NYDFS, Ms. Vullo’s background at the Office of the Attorney General, and New York State’s increasing reliance on the funds provided by enforcement actions, it is likely that the agency will continue to closely scrutinize foreign banks.
• Applying regulatory interface “best practices”, such as thorough exam preparation, managed exam interaction, and thoughtful regulatory engagement if concerns arise, are as critical as ever to reducing the risk of an NYDFS enforcement action.