Not that I wouldn’t love to be writing memos on NYPMIFA (New York’s peculiar version of UPMIFA), but some of the best in the (legal) business have already beat me to it.
Here are links to two very good memos on this topic that your CFOs and lawyers will want to see.
Simpson Thacher: http://www.simpsonthacher.com/content/publications/pub1062.pdf
Patterson Belknap: http://www.pbwt.com/resources/publications/new-york-version-of-upmifa/
Besides a memo from the Attorney General himself (which might be forthcoming), I don’t think you will find better legal authority in New York than these two firms.