Post written by Brian G. Shaffer, J.D. Candidate 2016, Pace Law School
The mission of the New York State Department of Financial Services (DFS) is “to reform the regulation of financial services in New York to keep pace with the rapid and dynamic evolution of these industries, to guard against financial crises and to protect consumers and markets from fraud.” To that end, DFS hosts a comprehensive web site, translatable to ninety languages through a translate feature at the top of the home page, that is searchable and simple to navigate. The site offers information and resources for consumers as well as the banking and insurance industries.
The DFS site contains a row of tabs from which users can link to the Department home page, an About Us tab, a Consumers tab, a tab dedicated to the Banking Industry, and another dedicated to the Insurance Industry, as well as a section for Legal information, each with subtabs. The home page prominently displays recent Department press releases, including a link to the DFS News Room, where users can find additional press releases, Superintendent’s letters, public hearings, and speeches and testimony. The home page also directs the user to recent developments, in addition to helpful one-click answers to frequently-asked questions, such as how to learn about mortgage escrow accounts. Department initiatives, including, for example, a Student Protection Unit and a Foreclosure Relief Unit, are also linked from the home page. In addition, the page offers useful quick links for consumers to file a complaint or for industry participants to learn about licensing and application processes.
The Consumers page immediately draws the user’s attention to important consumer alerts, which provide resources to help consumers with a wide variety of important skills, including how to understand credit scores, prepare for storms, and protect themselves in the event of data security breaches. The page also includes assistance for homeowners with mortgages and foreclosure, information about banking and saving, how to understand and compare insurance products, and how to recognize and report scams and fraud, among other resources helpful to consumers in managing their everyday financial affairs.
The Banking Industry page offers noticeably less content that the Consumers page, but the quality of the content is still quite good. The page offers links to forms and applications for banks and trusts and mortgage companies, and resources for financial services providers. Also provided is a link to The Weekly Banking Bulletin, with current issues and an archive from 2010 to date, which records applications and notices received by DFS, as well as actions taken by the Superintendent. The Banking Industry page also conspicuously links to the Consumers section.
The Insurance Industry page, like the Banking Industry page, is less voluminous than the Consumers section to which it conspicuously links. It also provides links to information, applications, forms and other resources for insurance companies as well as agents and brokers. The page additionally links to frequently-asked questions and the Company Complaint Response System, among other helpful resources for industry participants.
A Legal tab on the DFS site displays legal notices and provides links to proposed and final regulations and the regulatory agenda, the Department’s interpretations of laws and regulations, dating back as far as the 1960s, advisory letters, dating back to 1996, issued to clarify Department policies, agreements between the Department and other agencies, and legislative summaries that provide overviews of banking law and insurance-related bills. In addition, there is a link for users to make Freedom of Information (FOIL) requests in the event that they require records not found on the DFS site.
While the DFS site offers a search function, the user must perform a basic plain language search before gaining access to the site’s advanced search function. Once inside the advanced search, the user can narrow searches by word or phrase and exclude results with particular words in them, as well as narrow search results by language, format, number of occurrences of search terms, and domain. In addition, search results can be sorted by relevance or by date. Users can also choose to search for pages that link to a specific page.
The advanced search function on the DFS site is quite impressive, but its usefulness could be substantially improved if users could access it without first performing a basic search. Furthermore, in light of the site’s overall layout and copious provision of useful links arranged in an easy-to-follow tab/subtab/link format, the search function may actually be a less efficient means of navigating the site than following the funnel of links from the general area in which the user is interested down to the specific issue on which information is sought.
Although the DFS site offers information for consumers and industry participants, its overall tilt appears consumer oriented. While the site does allow industry professionals access to necessary materials, its provision of helpful explanatory resources seems in line with the general sentiment that the typical consumer is less sophisticated than the typical industry professional.