Date: November 25, 2015
To: Mr. Michael Paglialonga, New York Department of Labor
Filing Type: Regulatory
Description: CCMC believes that the new payroll card proposal by the NY DOL is an improvement over the initial proposal, however, there are still many provisions that discourage employers from offering and payroll card companies from providing, payroll cards. Additionally, the CFPB is expected to put forth a rulemaking in 2016 which would overly complicate the NY rule.