July 2023 - cypherpunks - lists.cpunks.org

Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 21 Jul '23

21 Jul '23

On Thu, Jul 20, 2023, 9:40 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > 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(a)xny.io> > *Sent:* Thursday, July 20, 2023 7:00 PM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; > cypherpunks(a)cpunks.org > *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness > (Extension Appeal) > > > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > > > On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g(a)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_guidan… > . > > > > 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(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > > >

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Fwd: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 21 Jul '23

21 Jul '23

---------- Forwarded message --------- From: Scott, Kathleen (DFS) <Kathleen.Scott(a)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(a)xny.io> Cc: dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>, cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>, Dean, Peter C (DFS) < Peter.Dean(a)dfs.ny.gov>, Tomczak, Christine (DFS) < christine.tomczak(a)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(a)xny.io> *Sent:* Thursday, July 20, 2023 7:00 PM *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; cypherpunks(a)cpunks.org *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal) *ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.* On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g(a)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_guidan… . 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(a)xNY.io +1-917-580-8053 New York, New York 10001

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 21 Jul '23

21 Jul '23

Bank.org. On Thu, Jul 20, 2023, 9:40 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > 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(a)xny.io> > *Sent:* Thursday, July 20, 2023 7:00 PM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; > cypherpunks(a)cpunks.org > *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness > (Extension Appeal) > > > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > > > On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g(a)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_guidan… > . > > > > 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(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > > >

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 21 Jul '23

21 Jul '23

You rock! 🏆 On Thu, Jul 20, 2023, 9:40 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > 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(a)xny.io> > *Sent:* Thursday, July 20, 2023 7:00 PM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; > cypherpunks(a)cpunks.org > *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness > (Extension Appeal) > > > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > > > On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g(a)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_guidan… > . > > > > 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(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > > >

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 20 Jul '23

20 Jul '23

On Thu, Jul 20, 2023, 6:36 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > Dear Mr. Larson > > I am in receipt of your messages and conferring on a response > > Very truly yours, > > Kathleen Scott > > > > *Kathleen A. Scott* > > Deputy Superintendent of Banking > > > > *New York State Department of Financial Services* > > One State Street Plaza, New York, NY 10004+1511 > > Phone: (212) 837-7321 | Fax: (212) 709-3520 | Mobile +1 (917) 538-3067 > > Kathleen.scott(a)dfs.ny.gov > > > > *www.dfs.ny.gov <http://www.dfs.ny.gov/>* > > > > > > > > > > > > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Thursday, July 20, 2023 6:34 PM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* cypherpunks(a)cpunks.org; Tomczak, Christine (DFS) < > christine.tomczak(a)dfs.ny.gov>; Harris, Adrienne A (DFS) < > Adrienne.Harris(a)dfs.ny.gov>; letitia.james(a)ag.ny.gov; > dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov> > *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness > (Extension Appeal) > > > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > > > On Thu, Jul 20, 2023, 5:28 PM Gunnar Larson <g(a)xny.io> wrote: > > > > On Sun, Jul 2, 2023, 6:38 AM Gunnar Larson <g(a)xny.io> wrote: > > Dear Ms. Scott: > > > > Today xNY.io - Bank.org asks NY-DFS to please reconsider deadline 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_guidan… > . > > > > 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 evidence of any documented > exceptions to compliance with the "Suggested Questions to Facilitate > Initial and Ongoing Assessment of Designated Persons’ Character and > Fitness." > > > > As Ms. Tomczak can confirm, xNY.io - Bank.org has a FOIL Request No. > 2022-090560 - Larson (NY-DFS Apple Card Investigation) appeal pending since > October 13, 2022. > > > > This last Friday, Bloomberg reported, "Goldman Sachs Is in Talks to Exit > Apple Partnership, WSJ Says" > https://www.bloomberg.com/news/articles/2023-06-30/goldman-sachs-is-in-talk… > . > > > > 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. > > > > Furthermore, xNY.io - Bank.org has 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 > > > > 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 'third' appeal > seeking extension for public comment to August 5, 2023? > > > > Sending you the very best from Chelsea. > > > > Thank you, > > > > Gunnar > > > > -- > > Gunnar Larson > > xNY.io | Bank.org > > MSc - Digital Currency > > MBA - Entrepreneurship and Innovation (ip) > > > > G(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > On Fri, Jun 30, 2023, 7:02 PM Gunnar Larson <g(a)xny.io> wrote: > > Dear Ms. Scott: > > > > Thank you for your response. > > > > Wishing you a great weekend ahead. > > > > Gunnar > > > > Gunnar Larson > > xNY.io - Bank.org > > 917-580-8053 > > > > On Fri, Jun 30, 2023, 4:59 PM Scott, Kathleen (DFS) < > Kathleen.Scott(a)dfs.ny.gov> wrote: > > Dear Mr. Larson, > > > > The Department has reviewed your request and at this time is not extending > the deadline for comment on the proposed guidance. > > > > For the avoidance of doubt, please note that the proposed guidance is not > asking anyone to complete the sample questionnaire. The sample > questionnaire is merely provided for review and comment by entities > regulated by the Department. > > > > Very truly yours, > > Kathleen Scott > > > > > > > > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Wednesday, June 28, 2023 12:05 AM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; > cypherpunks(a)cpunks.org > *Subject:* NY-DFS Proposed Guidance on Character and Fitness (Extension > Appeal) > > > > You don't often get email from g(a)xny.io. Learn why this is important > <https://aka.ms/LearnAboutSenderIdentification> > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > 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_guidan… > . > > > > 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(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > > >

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Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
by Gunnar Larson 20 Jul '23

20 Jul '23

Dear New York Ethics Team: I am concerned that the FOIL below is subject to obstruction of justice. The FOIL request is for access to NYPD body cam footage, for NYCCoin Touting. Ethics Team, I am concerned that the Chief of your office is also the Chief of the City Mayor's office. The body cam footage should have an agreeable time for delivery. I am concerned that the Mayor is retaliating against NYCoin and the NYPD may be aware of this. The video would or would not delineate any form of unnecessary force. The NYPD may be aware of this. Obviously, xNY is very protective of digital asset innovation. Ethics is a serious matter and the body cam footage would be helpful concerning NYCCoin. Sincerely yours, Gunnar Gunnar Larson xNY.io - Bank.org 917-580-8053 ---------- Forwarded message --------- From: <donotreply(a)records.nyc.gov> Date: Fri, Jul 14, 2023, 12:25 PM Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged To: <g(a)xny.io> The New York City Police Department (NYPD) has *acknowledged* your FOIL request FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>. You can expect a response on or about Wednesday, November 29, 2023. Additional Information: Your request has been assigned to PAA Quagliano (646-610-5296) Please visit FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> to view additional information and take any necessary action.

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Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
by Gunnar Larson 20 Jul '23

20 Jul '23

On Fri, Jul 14, 2023, 12:25 PM <donotreply(a)records.nyc.gov> wrote: > The New York City Police Department (NYPD) has *acknowledged* your FOIL > request FOIL-2023-056-15960 > <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>. > > You can expect a response on or about Wednesday, November 29, 2023. > Additional Information: > > Your request has been assigned to PAA Quagliano (646-610-5296) > > > Please visit FOIL-2023-056-15960 > <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> to > view additional information and take any necessary action. >

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 20 Jul '23

20 Jul '23

On Thu, Jul 20, 2023, 6:40 PM Gunnar Larson <g(a)xny.io> wrote: > Dear Ms. Scott: > > Bank.org welcomes you to the family. > > Gunnar > > On Thu, Jul 20, 2023, 6:36 PM Scott, Kathleen (DFS) < > Kathleen.Scott(a)dfs.ny.gov> wrote: > >> Dear Mr. Larson >> >> I am in receipt of your messages and conferring on a response >> >> Very truly yours, >> >> Kathleen Scott >> >> >> >> *Kathleen A. Scott* >> >> Deputy Superintendent of Banking >> >> >> >> *New York State Department of Financial Services* >> >> One State Street Plaza, New York, NY 10004+1511 >> >> Phone: (212) 837-7321 | Fax: (212) 709-3520 | Mobile +1 (917) 538-3067 >> >> Kathleen.scott(a)dfs.ny.gov >> >> >> >> *www.dfs.ny.gov <http://www.dfs.ny.gov/>* >> >> >> >> >> >> >> >> >> >> >> >> *From:* Gunnar Larson <g(a)xny.io> >> *Sent:* Thursday, July 20, 2023 6:34 PM >> *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> >> *Cc:* cypherpunks(a)cpunks.org; Tomczak, Christine (DFS) < >> christine.tomczak(a)dfs.ny.gov>; Harris, Adrienne A (DFS) < >> Adrienne.Harris(a)dfs.ny.gov>; letitia.james(a)ag.ny.gov; >> dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov> >> *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness >> (Extension Appeal) >> >> >> >> *ATTENTION: This email came from an external source. Do not open >> attachments or click on links from unknown senders or unexpected emails.* >> >> >> >> >> >> On Thu, Jul 20, 2023, 5:28 PM Gunnar Larson <g(a)xny.io> wrote: >> >> >> >> On Sun, Jul 2, 2023, 6:38 AM Gunnar Larson <g(a)xny.io> wrote: >> >> Dear Ms. Scott: >> >> >> >> Today xNY.io - Bank.org asks NY-DFS to please reconsider deadline 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_guidan… >> . >> >> >> >> 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 evidence of any documented >> exceptions to compliance with the "Suggested Questions to Facilitate >> Initial and Ongoing Assessment of Designated Persons’ Character and >> Fitness." >> >> >> >> As Ms. Tomczak can confirm, xNY.io - Bank.org has a FOIL Request No. >> 2022-090560 - Larson (NY-DFS Apple Card Investigation) appeal pending since >> October 13, 2022. >> >> >> >> This last Friday, Bloomberg reported, "Goldman Sachs Is in Talks to Exit >> Apple Partnership, WSJ Says" >> https://www.bloomberg.com/news/articles/2023-06-30/goldman-sachs-is-in-talk… >> . >> >> >> >> 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. >> >> >> >> Furthermore, xNY.io - Bank.org has 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 >> >> >> >> 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 'third' appeal >> seeking extension for public comment to August 5, 2023? >> >> >> >> Sending you the very best from Chelsea. >> >> >> >> Thank you, >> >> >> >> Gunnar >> >> >> >> -- >> >> Gunnar Larson >> >> xNY.io | Bank.org >> >> MSc - Digital Currency >> >> MBA - Entrepreneurship and Innovation (ip) >> >> >> >> G(a)xNY.io >> >> +1-917-580-8053 >> >> New York, New York 10001 >> >> >> >> On Fri, Jun 30, 2023, 7:02 PM Gunnar Larson <g(a)xny.io> wrote: >> >> Dear Ms. Scott: >> >> >> >> Thank you for your response. >> >> >> >> Wishing you a great weekend ahead. >> >> >> >> Gunnar >> >> >> >> Gunnar Larson >> >> xNY.io - Bank.org >> >> 917-580-8053 >> >> >> >> On Fri, Jun 30, 2023, 4:59 PM Scott, Kathleen (DFS) < >> Kathleen.Scott(a)dfs.ny.gov> wrote: >> >> Dear Mr. Larson, >> >> >> >> The Department has reviewed your request and at this time is not >> extending the deadline for comment on the proposed guidance. >> >> >> >> For the avoidance of doubt, please note that the proposed guidance is not >> asking anyone to complete the sample questionnaire. The sample >> questionnaire is merely provided for review and comment by entities >> regulated by the Department. >> >> >> >> Very truly yours, >> >> Kathleen Scott >> >> >> >> >> >> >> >> *From:* Gunnar Larson <g(a)xny.io> >> *Sent:* Wednesday, June 28, 2023 12:05 AM >> *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> >> *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; >> cypherpunks(a)cpunks.org >> *Subject:* NY-DFS Proposed Guidance on Character and Fitness (Extension >> Appeal) >> >> >> >> You don't often get email from g(a)xny.io. Learn why this is important >> <https://aka.ms/LearnAboutSenderIdentification> >> >> *ATTENTION: This email came from an external source. Do not open >> attachments or click on links from unknown senders or unexpected emails.* >> >> >> >> 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_guidan… >> . >> >> >> >> 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(a)xNY.io >> >> +1-917-580-8053 >> >> New York, New York 10001 >> >> >> >> >> >>

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 20 Jul '23

20 Jul '23

On Thu, Jul 20, 2023, 5:28 PM Gunnar Larson <g(a)xny.io> wrote: > > On Sun, Jul 2, 2023, 6:38 AM Gunnar Larson <g(a)xny.io> wrote: > >> Dear Ms. Scott: >> >> Today xNY.io - Bank.org asks NY-DFS to please reconsider deadline 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_guidan… >> . >> >> 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 evidence of any documented >> exceptions to compliance with the "Suggested Questions to Facilitate >> Initial and Ongoing Assessment of Designated Persons’ Character and >> Fitness." >> >> As Ms. Tomczak can confirm, xNY.io - Bank.org has a FOIL Request No. >> 2022-090560 - Larson (NY-DFS Apple Card Investigation) appeal pending since >> October 13, 2022. >> >> This last Friday, Bloomberg reported, "Goldman Sachs Is in Talks to Exit >> Apple Partnership, WSJ Says" >> https://www.bloomberg.com/news/articles/2023-06-30/goldman-sachs-is-in-talk… >> . >> >> 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. >> >> Furthermore, xNY.io - Bank.org has 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 >> >> 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 'third' appeal >> seeking extension for public comment to August 5, 2023? >> >> Sending you the very best from Chelsea. >> >> Thank you, >> >> Gunnar >> >> -- >> Gunnar Larson >> xNY.io | Bank.org >> MSc - Digital Currency >> MBA - Entrepreneurship and Innovation (ip) >> >> G(a)xNY.io >> +1-917-580-8053 >> New York, New York 10001 >> >> On Fri, Jun 30, 2023, 7:02 PM Gunnar Larson <g(a)xny.io> wrote: >> >>> Dear Ms. Scott: >>> >>> Thank you for your response. >>> >>> Wishing you a great weekend ahead. >>> >>> Gunnar >>> >>> Gunnar Larson >>> xNY.io - Bank.org >>> 917-580-8053 >>> >>> On Fri, Jun 30, 2023, 4:59 PM Scott, Kathleen (DFS) < >>> Kathleen.Scott(a)dfs.ny.gov> wrote: >>> >>>> Dear Mr. Larson, >>>> >>>> >>>> >>>> The Department has reviewed your request and at this time is not >>>> extending the deadline for comment on the proposed guidance. >>>> >>>> >>>> >>>> For the avoidance of doubt, please note that the proposed guidance is >>>> not asking anyone to complete the sample questionnaire. The sample >>>> questionnaire is merely provided for review and comment by entities >>>> regulated by the Department. >>>> >>>> >>>> >>>> Very truly yours, >>>> >>>> Kathleen Scott >>>> >>>> >>>> >>>> >>>> >>>> >>>> >>>> *From:* Gunnar Larson <g(a)xny.io> >>>> *Sent:* Wednesday, June 28, 2023 12:05 AM >>>> *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> >>>> *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; >>>> cypherpunks(a)cpunks.org >>>> *Subject:* NY-DFS Proposed Guidance on Character and Fitness >>>> (Extension Appeal) >>>> >>>> >>>> >>>> You don't often get email from g(a)xny.io. Learn why this is important >>>> <https://aka.ms/LearnAboutSenderIdentification> >>>> >>>> *ATTENTION: This email came from an external source. Do not open >>>> attachments or click on links from unknown senders or unexpected emails.* >>>> >>>> >>>> >>>> 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_guidan… >>>> . >>>> >>>> >>>> >>>> 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(a)xNY.io >>>> >>>> +1-917-580-8053 >>>> >>>> New York, New York 10001 >>>> >>>> >>>> >>>> >>>> >>>

1 0

Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 20 Jul '23

20 Jul '23

Dear Ms. Scott: Thank you for your response. Wishing you a great weekend ahead. Gunnar Gunnar Larson xNY.io - Bank.org 917-580-8053 On Fri, Jun 30, 2023, 4:59 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > Dear Mr. Larson, > > > > The Department has reviewed your request and at this time is not extending > the deadline for comment on the proposed guidance. > > > > For the avoidance of doubt, please note that the proposed guidance is not > asking anyone to complete the sample questionnaire. The sample > questionnaire is merely provided for review and comment by entities > regulated by the Department. > > > > Very truly yours, > > Kathleen Scott > > > > > > > > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Wednesday, June 28, 2023 12:05 AM > *To:* Scott, Kathleen (DFS) <Kathleen.Scott(a)dfs.ny.gov> > *Cc:* dfs.sm.BankingComments <BankingComments(a)dfs.ny.gov>; > cypherpunks(a)cpunks.org > *Subject:* NY-DFS Proposed Guidance on Character and Fitness (Extension > Appeal) > > > > You don't often get email from g(a)xny.io. Learn why this is important > <https://aka.ms/LearnAboutSenderIdentification> > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > 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_guidan… > . > > > > 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(a)xNY.io > > +1-917-580-8053 > > New York, New York 10001 > > > > >

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