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Empire Justice Comments to DFS on Vacant and Abandoned Properties

November 25, 2016

 

Celeste Koeleveld
New York State Department of Financial Services
One State Street
New York, NY 10004

Re:    Inspecting, Securing and Maintaining Vacant and Abandoned Residential Real Property
I.D. No. DFS-41-16-00006-P

Dear Ms. Koeleveld:

Thank you very much for the opportunity to submit comments regarding the New York State Department of Financial Services Proposed rule, 3 NYCRR 422 titled “Inspecting, Securing and Maintaining Vacant and Abandoned Residential Real Property,” published in the New York State Register October 12, 2016/Vol. XXXVIII, Issue 41 at 4-5.  We greatly appreciate the time and attention the NYS Department of Financial Services has invested in drafting these proposed rules and into the important issue of vacant and abandoned properties.
    
The proposed regulations are quite comprehensive and thoughtfully address most of what we agree needs to be included.  First, we will set forth general comments that apply more wholly to the regulations.  Second, we provide detailed comments for the sections of the regulations.  Finally, we provide herein suggestions for additional items to be addressed in regulation.

CLICK HERE to read our comments.

For more information, please contact:


Kirsten E. Keefe

Empire Justice Center
119 Washington Avenue
Albany, NY  12210 


(518) 462-6831
(518) 935-2852
kkeefe@empirejustice.org