Banking Interpretations

NYSBL  131(3) & 340

June 7, 2007


Dear Ms. [---]:

Your letter dated May 14, 2007 to the New York Banking Department, which concerns the proposed activities of your client in this state, has been referred to me for reply.  In your letter, you ask whether the conduct of these activities would require any application under the New York Banking Law.

According to your letter, your client is a Delaware corporation that intends to make loans to corporations in amounts ranging from $50,000 to $10,000,000 and offer other specified financial services to corporations in this state.  You state that your client will not enter into any consumer or retail lending arrangements.   Based on these facts, especially the statement that only corporations will receive loans and other services from your client, I am of the opinion that your client will not be required to obtain any license or other authorization from the New York Banking Department.

I trust that this letter is of assistance to you.


Steven Barras
First Assistant Counsel