USA – NEW YORK Trends and Developments Contributed by: Sam Davidson, Davidson Firm PLLC
that do not apply to a GLBA-exempt trust company; a state trust or bank will encounter prudential third-party management and oversight questions not applicable to a fintech platform it may interface with. Where these issues arise, reviews should involve cross-functional teams including legal, compliance, technology, prod - uct and risk management. Key assessment areas, to the extent applicable to the company’s operations, might include: • inventory of AI deployment; • documentation of personal data inputs; • allocation of pricing authority in partnership agree - ments; • analysis of exemption applicability; or • board-level oversight of AI deployment.
New York’s regulatory trajectory in 2026 reflects a wager: that transparency, accountability and gov - ernance discipline create a sustainable competitive advantage rather than counterproductive friction. For fintech companies, the question is how to strategical - ly position within it. In an environment where federal pre-emption remains uncertain and state consumer protection laws continue to rise, the jury is still out on whether New York’s legislative and enforcement approach ultimately fosters or constrains innovation and business growth.
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