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A New York registrant in 2026 offers copies rather than access to its safe and vaults. Do copies alone satisfy the superintendent statutory right of access?

Correct Answer

A) Insufficient: the superintendent has free access to safes and vaults

The superintendent and any duly designated representative shall have free access to the offices and places of business, books, accounts, papers, records, files, safes and vaults of all such licensees, servicers and registrants. Other choices: free access is to the places as well as the papers; certification does not substitute; and the right does not depend on a request for originals. Source: N.Y. Banking Law § 596

Answer Options
A
Insufficient: the superintendent has free access to safes and vaults
B
Insufficient only where the examiner asks for the originals
C
Sufficient, because the purpose of an examination is to review the records of the business and copies of those records convey everything that the originals would
D
Sufficient where the copies are certified by an officer

Why This Is the Correct Answer

The superintendent and any duly designated representative shall have free access to the offices and places of business, books, accounts, papers, records, files, safes and vaults of all such licensees, servicers and registrants. Other choices: free access is to the places as well as the papers; certification does not substitute; and the right does not depend on a request for originals. Source: N.Y. Banking Law § 596

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