In May 2012, the New York Appellate Division ruled that the Banking Department’s methodology for assessing mortgage bankers had not followed the State Administrative Procedures Act and was, therefore, invalid for fiscal year 2010. In response, the Department of Financial Services (into which the Banking Department and Insurance Department were consolidated in October 2011) has issued regulations setting forth how annual assessments are to be determined. For licensed brokers, lenders, and servicers, the formula considers a number of factors, including total gross revenues from New York operations, including servicing and secondary market revenues, for all licensees. The new methodology applies to assessments tied to the fiscal year starting April 1, 2011.