October 2024 - cypherpunks - lists.cpunks.org

NY's Financial Regulator Releases AI Cybersecurity Guidance
by Gunnar Larson 17 Oct '24

17 Oct '24

NY's Financial Regulator Releases AI Cybersecurity Guidance <https://www.law360.com/technology/articles/1890640?nl_pk=2bd720dd-746c-4744…> By Sarah Jarvis New York's Department of Financial Services issued new guidance Wednesday intended to give state-regulated financial institutions an outline for protecting against cybersecurity risks posed by artificial intelligence. Read full article » <https://www.law360.com/technology/articles/1890640?nl_pk=2bd720dd-746c-4744…> | Save to favorites » <https://www.law360.com/technology/articles/1890640?nl_pk=2bd720dd-746c-4744…>

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Could Big Tech Own Federally-Insured Banks? Here Are the Dangers
by Gunnar Larson 17 Oct '24

17 Oct '24

https://wallstreetonparade.com/2024/10/could-big-tech-own-federally-insured… By Pam Martens and Russ Martens: October 17, 2024 ~ Broken Piggy BankThe risk of Big Tech firms like Alphabet (Google), Amazon, Apple, Meta (Facebook), and Microsoft getting an entrée into the federally-insured banking system by being allowed to buy or create a federally-insured industrial bank has raised alarm bells among three nonprofit watchdogs and the law professor who, literally, wrote the book on the mushrooming systemic risks in the U.S. banking system. Arthur E. Wilmarth, Jr., Professor Emeritus of Law at George Washington University Law School, joined with the Consumer Federation of America, Americans for Financial Reform Education Fund, and the Center for Responsible Lending, to file an 18-page letter last Friday with the Federal Deposit Insurance Corporation (FDIC). (For background on Wilmarth’s seminal book, see our report: Everything this Book Predicted on Wall Street Megabanks Ruling their Regulators Is Now Unfolding.) Friday’s letter was in response to the FDIC’s proposal to improve oversight of so-called “industrial banks,” which are allowed to skirt the Congressional mandate that prohibits the mixing of banking and commerce. From 2006 to 2020, the FDIC had imposed a moratorium on new approvals of industrial banks. That moratorium was lifted in 2020. The letter reminds the FDIC of the recent history of emergency bailouts to the corporate parents of industrial banks, writing: “Several large corporate owners of industrial banks failed or were rescued by the federal government during the global financial crisis of 2007-09, and the total number of industrial banks fell from 58 in 2007 to 23 today. Four very large corporate owners of industrial banks—General Motors Acceptance Corp. (GMAC), Merrill Lynch, Goldman Sachs, and Morgan Stanley—received huge bailouts from the federal government to prevent their failures. A fifth major industrial bank owner—GE Capital—encountered very serious liquidity problems during the crisis and received extensive financial assistance from federal agencies. A sixth corporate industrial bank owner—CIT Group—failed in 2009, thereby wiping out $2.3 billion of taxpayer-funded assistance that CIT received from the federal government’s Troubled Asset Relief Program (TARP)….” Big Tech already possesses vast, Orwellian profiles of consumers. The letter captures the threat of combining that with banking as follows: “Acquisitions of industrial banks by Big Tech firms would present a wide array of public policy issues, including concerns about unfair competition, exploitation of customer financial data, violations of customer privacy, and systemic risks resulting from ownership of FDIC-insured banks by giant technology firms. The combination of Big Tech companies’ massive datasets of consumer preferences and purchases with the extensive consumer financial information compiled by FDIC-insured industrial banks would greatly expand the reach of Big Tech firms into consumers’ finances by giving them greater insight into household income and spending patterns and would allow the combined firms to more fully exploit such data for commercial purposes while undermining consumer privacy. Further, Big Tech firms could condition or preference access by consumers and merchants to their digital commercial platforms or rewards programs on the willingness of those customers to use the financial services of their captive or shell industrial banks. Allowing a Big Tech firm to link its commercial platform with an industrial bank would allow the Big Tech firm to combine customer and merchant data to set bespoke, higher prices on transactions in the form of first-degree price discrimination that would benefit the platform while extracting unfair surplus value from consumers and merchants. The BHC Act [Bank Holding Company Act] prohibits banks from processing, storing, or sharing data that is not ‘financial, banking, or economic’ if that nonbanking data processing, storing, and transmission revenues exceed 49 percent of the bank’s total revenues, which would likely be the case with Big Tech shell or captive industrial banks.” The letter’s authors also foresee a competition war breaking out between Wall Street’s megabanks and Big Tech’s banks should the separation walls be removed between commerce and banking. They write: “Acquisitions of industrial banks by Big Tech firms would also generate intense political pressure on Congress to repeal the BHC Act’s restrictions on joint ownership of banks and commercial firms. Big Tech firms would not be satisfied with making ‘toehold’ acquisitions of industrial banks. They would push to build a bigger competitive presence in the U.S. financial industry by acquiring full-service commercial banks. Conversely, large commercial banks would argue that Congress must create a ‘level playing field’ that would allow commercial banks to acquire technology firms. Thus, allowing Big Tech firms to acquire industrial banks would probably lead to federal legislation allowing unrestricted combinations between giant technology firms and major banks. Such combinations would magnify the problems our nation already faces due to excessive levels of concentration and market power in our banking and information technology sectors as well as the dangerous political and regulatory influence that our technology giants and largest banks currently command and exploit.” The nonprofit watchdog, Public Citizen, has been ringing the alarm bells for years about the stealthy and dangerous combination of banking and commerce at JPMorgan Chase – the largest federally-insured bank in the United States with $3.5 trillion in assets as of June 30. See our report: Watchdog to Fed: JPMorgan Is Controlling Fossil Fuels Empire, Which Just Spilled a Million Gallons of Oil in Gulf of Mexico. These unprecedented concentrations of market power bring to mind what the late Supreme Court Justice, Louis Brandeis, presciently stated: “We can have democracy in this country, or we can have great wealth concentrated in the hands of a few, but we can’t have both.” If American democracy increasingly feels like an out-of-control kleptocracy to you, look no further than the Brandeis warning and the U.S. Supreme Court’s Citizens United decision which opened the floodgates to corporate money in political campaigns. And for what Facebook already attempted to pull off in the financial system in 2019, but failed, see our report: Senator Compares Facebook’s Libra Association to Spectre in James Bond Movie.

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Utah Judge Tosses Mattress Conspiracy Suit For Good
by Gunnar Larson 17 Oct '24

17 Oct '24

Utah Judge Tosses Mattress Conspiracy Suit For Good <https://www.law360.com/competition/articles/1890668?nl_pk=6416fd97-1dc4-4e0…> By Matthew Perlman A Utah federal court has tossed a lawsuit accusing major mattress companies and a trade group of conspiring to drive a competitor from the market after finding a lack of evidence showing there was an agreement to harm competition and saying the claims can't be fixed. Order attached | Read full article » <https://www.law360.com/competition/articles/1890668?nl_pk=6416fd97-1dc4-4e0…> | Save to favorites » <https://www.law360.com/competition/articles/1890668?nl_pk=6416fd97-1dc4-4e0…>

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Re: Bloomberg Coinbase Interview
by Gunnar Larson 17 Oct '24

17 Oct '24

Michael: Okay. Can you ask around the office and get back to me, given the event tonight in New York City? Thank you, Gunnar ✌️ On Thu, Oct 17, 2024, 2:04 PM Michael Briody (BLOOMBERG/ 731 LEX) < mbriody4(a)bloomberg.net> wrote: > Not that I am aware of.. > > Michael J. Briody > Bloomberg Financial L.P. > FX & Crypto Markets Specialist > Twitter: @BriodyMike > Linkedin: www.linkedin.com/in/michaeljbriody > > From: g(a)xny.io At: 10/17/24 13:41:12 UTC-4:00 > To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> > Cc: Francesco Tonin (BLOOMBERG/ 731 LEX ) <ftonin5(a)bloomberg.net>, > cypherpunks(a)lists.cpunks.org > Subject: Re: Bloomberg Coinbase Interview > > Michael: > > I am wondering if our last correspondence specific to the Bloomberg > Coinbase interview had anything to do with the Bloomberg event in Chicago > yesterday? > > All the best, > > Gunnar ✌️ > -- > Gunnar Larson > xNY.io - Bank.org > 917-580-8053 > > > On Thu, Oct 17, 2024, 1:22 PM Michael Briody (BLOOMBERG/ 731 LEX) < > mbriody4(a)bloomberg.net> wrote: > >> Hi Gunnar, >> >> If would like to be more specific on the nature of the catch up I can try >> to put you in touch with the appropriate person as I do not work in the >> news division. >> >> Regards, >> Mike >> >> Michael J. Briody >> Bloomberg Financial L.P. >> FX & Crypto Markets Specialist >> Twitter: @BriodyMike >> Linkedin: www.linkedin.com/in/michaeljbriody >> >> From: g(a)xny.io At: 10/17/24 11:50:24 UTC-4:00 >> To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> >> Cc: cypherpunks(a)lists.cpunks.org >> Subject: Re: Bloomberg Coinbase Interview >> >> Michael: >> >> I am watching this Bloomberg Live interview now (Former US President and >> Republican presidential nominee Donald Trump discusses his economic >> policies, immigration and the 2024 US presidential election. Bloomberg News >> Editor-in-Chief John Micklethwait speaks to Trump at an event with the >> Economic Club of Chicago): >> https://youtu.be/MyaHbUmVll4?si=d9P4EnfJu3NPajt0. >> >> Before I get ahead of myself in watching Bloomberg's journalism yesterday >> (and, for plausible deniability), I feel implored to re-investigate our >> last January 31, 2023 e-mail correspondence together. >> >> Michael, are you available to have a phone conversation today or tomorrow? >> >> Warm regards, >> >> Gunnar ✌️ >> -- >> Gunnar Larson >> xNY.io - Bank.org >> 917-580-8053 >> >> >> On Tue, Jan 31, 2023, 8:09 PM Gunnar Larson <g(a)xny.io> wrote: >> >>> No big deal. >>> >>> Was just a thought. >>> >>> Have a great night, >>> >>> Gunnar >>> >>> On Tue, Jan 31, 2023, 7:56 PM Michael Briody (BLOOMBERG/ 731 LEX) < >>> mbriody4(a)bloomberg.net> wrote: >>> >>>> Yes I saw it, I thought it was a good conversation. I am on the product >>>> side of the the business you would have to reach out to legal via the >>>> website. >>>> >>>> best, >>>> Mike >>>> >>>> Michael J. Briody >>>> Bloomberg Financial L.P. >>>> FX & Crypto Markets Specialist >>>> Twitter: @BriodyMike >>>> Linkedin: www.linkedin.com/in/michaeljbriody >>>> >>>> From: g(a)xny.io At: 01/31/23 19:04:59 UTC-5:00 >>>> To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> >>>> Subject: Bloomberg Coinbase Interview >>>> >>>> Dear Mike: >>>> >>>> Did you watch the interview on the David Rubenstein Show: Coinbase's >>>> Brian Armstrong Bloomberg.com: >>>> https://www.bloomberg.com/news/videos/2023-01-12/the-david-rubenstein-show-… >>>> >>>> The interview was done last December, before the 100M settlement was >>>> done with NY-DFS. In the interview, Mr. Armstrong makes several false >>>> claims to Coinbase's compliance and overall integrity. >>>> >>>> This is somewhat problematic with overall integrity to their future of >>>> digital asset innovation cross border. xNY.io - Bank.org was thinking of >>>> exploring New York's false claims act on the interview. >>>> >>>> Wanted to see if Bloomberg wanted to join us on this pursuit? >>>> >>>> Thank you, >>>> >>>> Gunnar >>>> >>>> Gunnar Larson >>>> xNY.io - Bank.org >>>> 646-454-9107 >>>> >>>> >>>> >> >

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 17 Oct '24

17 Oct '24

Ms. Scott: Okay. Thank you for the update. Have a great day and appreciate your help. Thank you, Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Thu, Oct 17, 2024, 1:54 PM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > Dear Mr. Larson, > > The guidance > <https://www.dfs.ny.gov/industry_guidance/industry_letters/il20240122_guidan…> > was finalized and published on our website on January 22, 2024. > > > > Regards, > > 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, October 17, 2024 12:02 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>; dfs.sm.BankingComments < > BankingComments(a)dfs.ny.gov>; Dean, Peter C (DFS) <Peter.Dean(a)dfs.ny.gov>; > Reader, Shaun <sreader(a)curtis.com>; cypherpunks < > cypherpunks(a)lists.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.* > > > > Dear Ms. Scott: > > > > Thank you for your response below on July 5, 2023. > > > > Can you advise if DFS is still taking comments related to the proposed > Character and Fitness given the events of October 16, 2024 at the Economic > Club of Chicago? > > > > You can find Bloomberg's YouTube link here: > https://youtu.be/MyaHbUmVll4?si=TlrmIVkADTiQO_PL > > > > Ms. Scott, between July 5, 2023 and October 16, 2024 xNY.io - Bank.org > fears DFS is acting nefariously against New Yorkers' best interests. > > > > Additional time for comment seems warrented. > > > > Warm regards, > > > > Gunnar > > -- > > Gunnar Larson > > xNY.io - Bank.org > > 917-580-8053 > > > > On Wed, Jul 5, 2023, 11:32 AM Scott, Kathleen (DFS) < > Kathleen.Scott(a)dfs.ny.gov> wrote: > > Dear Mr. Larson > > The Department has not extended the deadline on comments on the proposed > Character and Fitness guidance. > > Very truly yours > > Kathleen Scott > > > > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Sunday, July 2, 2023 6:38 AM > *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) > > > > 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.* > > > > 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: Bloomberg Coinbase Interview
by Gunnar Larson 17 Oct '24

17 Oct '24

Michael: I am wondering if our last correspondence specific to the Bloomberg Coinbase interview had anything to do with the Bloomberg event in Chicago yesterday? All the best, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Thu, Oct 17, 2024, 1:22 PM Michael Briody (BLOOMBERG/ 731 LEX) < mbriody4(a)bloomberg.net> wrote: > Hi Gunnar, > > If would like to be more specific on the nature of the catch up I can try > to put you in touch with the appropriate person as I do not work in the > news division. > > Regards, > Mike > > Michael J. Briody > Bloomberg Financial L.P. > FX & Crypto Markets Specialist > Twitter: @BriodyMike > Linkedin: www.linkedin.com/in/michaeljbriody > > From: g(a)xny.io At: 10/17/24 11:50:24 UTC-4:00 > To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> > Cc: cypherpunks(a)lists.cpunks.org > Subject: Re: Bloomberg Coinbase Interview > > Michael: > > I am watching this Bloomberg Live interview now (Former US President and > Republican presidential nominee Donald Trump discusses his economic > policies, immigration and the 2024 US presidential election. Bloomberg News > Editor-in-Chief John Micklethwait speaks to Trump at an event with the > Economic Club of Chicago): > https://youtu.be/MyaHbUmVll4?si=d9P4EnfJu3NPajt0. > > Before I get ahead of myself in watching Bloomberg's journalism yesterday > (and, for plausible deniability), I feel implored to re-investigate our > last January 31, 2023 e-mail correspondence together. > > Michael, are you available to have a phone conversation today or tomorrow? > > Warm regards, > > Gunnar ✌️ > -- > Gunnar Larson > xNY.io - Bank.org > 917-580-8053 > > > On Tue, Jan 31, 2023, 8:09 PM Gunnar Larson <g(a)xny.io> wrote: > >> No big deal. >> >> Was just a thought. >> >> Have a great night, >> >> Gunnar >> >> On Tue, Jan 31, 2023, 7:56 PM Michael Briody (BLOOMBERG/ 731 LEX) < >> mbriody4(a)bloomberg.net> wrote: >> >>> Yes I saw it, I thought it was a good conversation. I am on the product >>> side of the the business you would have to reach out to legal via the >>> website. >>> >>> best, >>> Mike >>> >>> Michael J. Briody >>> Bloomberg Financial L.P. >>> FX & Crypto Markets Specialist >>> Twitter: @BriodyMike >>> Linkedin: www.linkedin.com/in/michaeljbriody >>> >>> From: g(a)xny.io At: 01/31/23 19:04:59 UTC-5:00 >>> To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> >>> Subject: Bloomberg Coinbase Interview >>> >>> Dear Mike: >>> >>> Did you watch the interview on the David Rubenstein Show: Coinbase's >>> Brian Armstrong Bloomberg.com: >>> https://www.bloomberg.com/news/videos/2023-01-12/the-david-rubenstein-show-… >>> >>> The interview was done last December, before the 100M settlement was >>> done with NY-DFS. In the interview, Mr. Armstrong makes several false >>> claims to Coinbase's compliance and overall integrity. >>> >>> This is somewhat problematic with overall integrity to their future of >>> digital asset innovation cross border. xNY.io - Bank.org was thinking of >>> exploring New York's false claims act on the interview. >>> >>> Wanted to see if Bloomberg wanted to join us on this pursuit? >>> >>> Thank you, >>> >>> Gunnar >>> >>> Gunnar Larson >>> xNY.io - Bank.org >>> 646-454-9107 >>> >>> >>> >

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Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 17 Oct '24

17 Oct '24

Dear Ms. Scott: Thank you for your response below on July 5, 2023. Can you advise if DFS is still taking comments related to the proposed Character and Fitness given the events of October 16, 2024 at the Economic Club of Chicago? You can find Bloomberg's YouTube link here: https://youtu.be/MyaHbUmVll4?si=TlrmIVkADTiQO_PL Ms. Scott, between July 5, 2023 and October 16, 2024 xNY.io - Bank.org fears DFS is acting nefariously against New Yorkers' best interests. Additional time for comment seems warrented. Warm regards, Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Wed, Jul 5, 2023, 11:32 AM Scott, Kathleen (DFS) < Kathleen.Scott(a)dfs.ny.gov> wrote: > Dear Mr. Larson > > The Department has not extended the deadline on comments on the proposed > Character and Fitness guidance. > > Very truly yours > > Kathleen Scott > > > > *From:* Gunnar Larson <g(a)xny.io> > *Sent:* Sunday, July 2, 2023 6:38 AM > *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) > > > > 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.* > > > > 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: Bloomberg Coinbase Interview
by Gunnar Larson 17 Oct '24

17 Oct '24

Michael: I am watching this Bloomberg Live interview now (Former US President and Republican presidential nominee Donald Trump discusses his economic policies, immigration and the 2024 US presidential election. Bloomberg News Editor-in-Chief John Micklethwait speaks to Trump at an event with the Economic Club of Chicago): https://youtu.be/MyaHbUmVll4?si=d9P4EnfJu3NPajt0. Before I get ahead of myself in watching Bloomberg's journalism yesterday (and, for plausible deniability), I feel implored to re-investigate our last January 31, 2023 e-mail correspondence together. Michael, are you available to have a phone conversation today or tomorrow? Warm regards, Gunnar ✌️ -- Gunnar Larson xNY.io - Bank.org 917-580-8053 On Tue, Jan 31, 2023, 8:09 PM Gunnar Larson <g(a)xny.io> wrote: > No big deal. > > Was just a thought. > > Have a great night, > > Gunnar > > On Tue, Jan 31, 2023, 7:56 PM Michael Briody (BLOOMBERG/ 731 LEX) < > mbriody4(a)bloomberg.net> wrote: > >> Yes I saw it, I thought it was a good conversation. I am on the product >> side of the the business you would have to reach out to legal via the >> website. >> >> best, >> Mike >> >> Michael J. Briody >> Bloomberg Financial L.P. >> FX & Crypto Markets Specialist >> Twitter: @BriodyMike >> Linkedin: www.linkedin.com/in/michaeljbriody >> >> From: g(a)xny.io At: 01/31/23 19:04:59 UTC-5:00 >> To: Michael Briody (BLOOMBERG/ 731 LEX ) <mbriody4(a)bloomberg.net> >> Subject: Bloomberg Coinbase Interview >> >> Dear Mike: >> >> Did you watch the interview on the David Rubenstein Show: Coinbase's >> Brian Armstrong Bloomberg.com: >> https://www.bloomberg.com/news/videos/2023-01-12/the-david-rubenstein-show-… >> >> The interview was done last December, before the 100M settlement was done >> with NY-DFS. In the interview, Mr. Armstrong makes several false claims to >> Coinbase's compliance and overall integrity. >> >> This is somewhat problematic with overall integrity to their future of >> digital asset innovation cross border. xNY.io - Bank.org was thinking of >> exploring New York's false claims act on the interview. >> >> Wanted to see if Bloomberg wanted to join us on this pursuit? >> >> Thank you, >> >> Gunnar >> >> Gunnar Larson >> xNY.io - Bank.org >> 646-454-9107 >> >> >>

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Fwd: Orbisa on US 20y Bond
by Gunnar Larson 17 Oct '24

17 Oct '24

---------- Forwarded message --------- From: EquiLend News <clientcommunications(a)equilend.com> Date: Thu, Oct 17, 2024, 5:54 AM Subject: Orbisa on US 20y Bond To: <G(a)xny.io> <https://go.equilend.com/e/928823/2024-10-17/j35cc3/842825783/h/q-zAXaVKIijG…> *Orbisa Take Notes on the US 20-Year Bond* As you attended our Bloomberg seminar on Orbisa, you may be interested in more securities lending insights. Today, we bring you our latest analytical piece in the Orbisa Take Notes series, diving into the latest market movements seen in A new focus for Orbisa Take Notes with a focus on fixed income, Orbisa has observed significant securities lending activity for the August 15th 2024 issuance of the United States 20-year bond (4.125% US912810UD80). The US 20y was the second highest revenue generating security in the month of September <https://go.equilend.com/e/928823/ar-to-2-49-billion-in-q3-2024-/j35cc6/8428…> as the US federal reserve moved to cut interest rates by 50 basis points. Orbisa continues to see strong demand for the bond with $5.7 billion of the issuance actively being borrowed, representing nearly 65% of the total supply available to be lent. Click Here to Start Your Free Trial of Orbisa on Bloomberg Today! <https://go.equilend.com/e/928823/screens-apps20orbisa/j35cc9/842825783/h/q-…> [image: Orbisa Take Notes on the US 20-Year Bond] <https://go.equilend.com/e/928823/tm-campaign-TakeNotes-20Y-Bond/j35ccd/8428…> Click Here to Dive into Orbisa Take Notes on the US 20-Year Bond <https://go.equilend.com/e/928823/tm-campaign-TakeNotes-20Y-Bond/j35ccd/8428…> Orbisa (the “Firm”) is not registered as an investment advisor or otherwise in any capacity with any securities regulatory authority. The information contained, referenced or linked to herein is proprietary and exclusive to the Firm, does not constitute investment or trading advice, is provided for general information and discussion purposes only and may not be copied or redistributed without the Firm’s prior written consent. The Firm assumes no responsibility or liability for the unauthorized use of any information contained, referenced or linked to herein. © 2024 EquiLend Holdings LLC. All rights reserved. Unsubscribe <https://go.equilend.com/unsubscribe/u/928823/79c841ab5e11a0b553270517f6f862…>

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3rd Par Funding Exec Admits To Racketeering In $100M Scam
by Gunnar Larson 17 Oct '24

17 Oct '24

3rd Par Funding Exec Admits To Racketeering In $100M Scam <https://www.law360.com/banking/articles/1890819?nl_pk=feb6bbba-7878-4d39-be…> By P.J. D'Annunzio The last member of the triumvirate behind Par Funding, a cash advance company that federal prosecutors say bilked investors out of $100 million, pleaded guilty to racketeering in Pennsylvania federal court Wednesday, just weeks before he was scheduled to stand trial. Read full article » <https://www.law360.com/banking/articles/1890819?nl_pk=feb6bbba-7878-4d39-be…> | Save to favorites » <https://www.law360.com/banking/articles/1890819?nl_pk=feb6bbba-7878-4d39-be…>

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