Equipment Leasing and Finance Association - Equiping Business for Success

Other Issues

Issue Overview

In addition to the policy areas highlighted on our State Advocacy Webpage, ELFA also monitors and engages on many other areas that impact the equipment leasing and finance industry. Below is a sampling of advocacy materials created and used by ELFA in the past.

Cybersecurity


  • New York | Opposition Testimony for Cybersecurity Proposal. ELFA submitted opposition testimony before the New York Assembly Committee on Banking in December 2016, when a hearing was called to review a proposed Department of Financial Services cybersecurity regulation that ELFA faults as being an overly prescriptive, a one-size-fits-all regulation, and that ultimately fails to take into account multiple standards that already exist and are being implemented successfully.
  • New York | Comments Urging Department of Financial Services to Reconsider Proposed Cybersecurity Requirements. In November 2016, ELFA submitted comments to the NYDFS urging reconsideration of certain proposed cybersecurity requirements that set rigid minimum standards which, in some cases, exceed existing regulatory guidance and industry practices, and fail to account for the varying sizes, resources, and types of financial services companies operating in New York.

General Leasing


Securitization


Storage and Retention of Records


Terminal Rental Adjustment Clause (TRAC) Legislation


  • American Automotive Leasing Association Memo on TRAC Statutes by State.
    An August 2015 memo prepared by the American Automotive Leasing Association outlines TRAC state statutes in each of the 50 states.
  • State TRAC Law Citations (as of September 2011). The TRAC state law citations are offered solely for the convenience and easy reference of the reader and not as legal advice. Each company or individual should consult with its own lawyer to check the accuracy of the citation.
  • Kentucky TRAC Legislation. In 2012, Kentucky enacted TRAC legislation found in Section 101 of Senate Bill 97. Upon implementation it allowed for the up or down adjustment of rent to accommodate a difference between projected value of a vehicle and its actual value upon lease termination.