Fwd: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)

[Gunnar Larson]

---------- Forwarded message ---------
From: Scott, Kathleen (DFS) <Kathleen.Scott at dfs.ny.gov>
Date: Thu, Jul 20, 2023, 9:40 PM
Subject: RE: NY-DFS Proposed Guidance on Character and Fitness (Extension
Appeal)
To: Gunnar Larson <g at xny.io>
Cc: dfs.sm.BankingComments <BankingComments at dfs.ny.gov>,
cypherpunks at cpunks.org <cypherpunks at cpunks.org>, Dean, Peter C (DFS) <
Peter.Dean at dfs.ny.gov>, Tomczak, Christine (DFS) <
christine.tomczak at dfs.ny.gov>


Dear Mr. Larson

I have conferred with our General Counsel and while the comment period has
closed, we thank you for your interest and will accept and review whatever
you wish to submit even though it is beyond the comment period

Very truly yours

Kathleen Scott

*From:* Gunnar Larson <g at xny.io>
*Sent:* Thursday, July 20, 2023 7:00 PM
*To:* Scott, Kathleen (DFS) <Kathleen.Scott at dfs.ny.gov>
*Cc:* dfs.sm.BankingComments <BankingComments at dfs.ny.gov>;
cypherpunks at cpunks.org
*Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness (Extension
Appeal)



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On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g at xny.io> wrote:

Ms. Scott:



NY-DFS recently asked for public comment concerning "Proposed Guidance on
Assessment of the Character and Fitness of Directors, Senior Officers, and
Managers" mentioned here:
https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidance_assessment_fitness
.



xNY.io - Bank.org asks if the NY-DFS will extend deadline for public
comment to August 5, 2023 from June 30, 2023.



As requested by NY-DFS, today we provide (in a separate attachment)
evidence of any documented exceptions to compliance with the "Suggested
Questions to Facilitate Initial and Ongoing Assessment of Designated
Persons’ Character and Fitness."



We have collated 19 references comprising 205 highlights that touch on the
five key areas below:
https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO.



-Harassment and Discrimination Policies



-Conflict of Interest Policy



-Insider Trading Policy



-Records Management Policy



-Corporate Opportunity Policy



xNY.io - Bank.org is seeking NY-DFS' extension for public comment to August
5, 2023 so that the New York Banking community has time to complete Q2-23
earnings call disclosures.



As documented in the above 19 references, we feel extra time for public
comment is warranted to ensure that xNY.io - Bank.org did not play a
significant role or otherwise contribute in a meaningful way to the conduct
that led to regulatory action or proceeding without ample notice.



Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and
Ongoing Assessment of Designated Persons’ Character and Fitness," can you
kindly acknowledge that you have reviewed and understand our appeal seeking
extension for public comment to August 5, 2023?



We hope to hear from you before June 30, 2023 given obvious factors.



Sending you the very best regards.



Thank you,



Gunnar



--

Gunnar Larson

xNY.io | Bank.org

MSc - Digital Currency

MBA - Entrepreneurship and Innovation (ip)



G at xNY.io

+1-917-580-8053

New York, New York 10001
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