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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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TD Bank's $3B AML Deal Sparks Scrutiny Of Its Oversight
by Gunnar Larson 17 Oct '24

17 Oct '24

TD Bank's $3B AML Deal Sparks Scrutiny Of Its Oversight <https://www.law360.com/banking/articles/1890553?nl_pk=feb6bbba-7878-4d39-be…> By Jon Hill The long-standing, widespread compliance failures at the root of TD Bank's blockbuster $3 billion U.S. anti-money laundering settlement last week have stunned experts and brought tough punishment for the Canadian bank — but they're also raising questions about why regulators didn't act sooner. Read full article » <https://www.law360.com/banking/articles/1890553?nl_pk=feb6bbba-7878-4d39-be…> | Save to favorites » <https://www.law360.com/banking/articles/1890553?nl_pk=feb6bbba-7878-4d39-be…>

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Feds Say EMTALA Trumps Idaho Abortion Ban In Emergencies
by Gunnar Larson 17 Oct '24

17 Oct '24

Feds Say EMTALA Trumps Idaho Abortion Ban In Emergencies <https://www.law360.com/health/articles/1890543?nl_pk=6422bbc2-a823-4be5-9a9…> By Mark Payne A legal fight over a federal law governing emergency medical care and Idaho's strict abortion ban is back in the Ninth Circuit where the federal government argued that the ban conflicts with the federal statute, but only in narrow circumstances requiring emergency abortions to stabilize a pregnant woman. Brief attached | Read full article » <https://www.law360.com/health/articles/1890543?nl_pk=6422bbc2-a823-4be5-9a9…> | Save to favorites » <https://www.law360.com/health/articles/1890543?nl_pk=6422bbc2-a823-4be5-9a9…>

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Insurer Gets Philly Eagles' COVID-19 Coverage Suit Tossed
by Gunnar Larson 17 Oct '24

17 Oct '24

Insurer Gets Philly Eagles' COVID-19 Coverage Suit Tossed <https://www.law360.com/insurance/articles/1890747?nl_pk=59612751-8689-4b1e-…> By Hope Patti A Pennsylvania federal court on Wednesday tossed the Philadelphia Eagles' suit seeking to recover pandemic-related losses from Factory Mutual Insurance Co., citing a recent Pennsylvania Supreme Court holding that physical loss or damage requires tangible alteration to property. Order attached | Read full article » <https://www.law360.com/insurance/articles/1890747?nl_pk=59612751-8689-4b1e-…> | Save to favorites » <https://www.law360.com/insurance/articles/1890747?nl_pk=59612751-8689-4b1e-…>

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Bitfinex Hacker Deserves 5 Years For Crypto Heist, Feds Say
by Gunnar Larson 17 Oct '24

17 Oct '24

Bitfinex Hacker Deserves 5 Years For Crypto Heist, Feds Say <https://www.law360.com/fintech/articles/1890526?nl_pk=d2b3e7ef-ab62-4a62-80…> By Aislinn Keely The hacker who stole bitcoin now worth billions of dollars from crypto exchange Bitfinex should serve just 60 months for the exploit and subsequent laundering of the funds because his post-arrest cooperation "benefitted numerous investigations" and merits a below-guidelines sentence, prosecutors told a federal judge. Motion attached | Read full article » <https://www.law360.com/fintech/articles/1890526?nl_pk=d2b3e7ef-ab62-4a62-80…> | Save to favorites » <https://www.law360.com/fintech/articles/1890526?nl_pk=d2b3e7ef-ab62-4a62-80…>

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NYSE Seeks To Curb Reverse Splits In Latest Crackdown
by Gunnar Larson 17 Oct '24

17 Oct '24

NYSE Seeks To Curb Reverse Splits In Latest Crackdown <https://www.law360.com/mergersacquisitions/articles/1890634?nl_pk=a34c25b5-…> By Tom Zanki The New York Stock Exchange wants to limit companies' ability to rely on reverse stock splits to raise their share prices and avoid delisting, submitting a proposal shortly after regulators approved a Nasdaq plan to rein in such splits. Proposed Rule attached | Read full article » <https://www.law360.com/mergersacquisitions/articles/1890634?nl_pk=a34c25b5-…> | Save to favorites » <https://www.law360.com/mergersacquisitions/articles/1890634?nl_pk=a34c25b5-…>

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Sudanese Men Charged With Hacking Cedars-Sinai, Microsoft
by Gunnar Larson 17 Oct '24

17 Oct '24

Sudanese Men Charged With Hacking Cedars-Sinai, Microsoft <https://www.law360.com/technology/articles/1890735?nl_pk=2bd720dd-746c-4744…> By Rachel Scharf California federal prosecutors announced Wednesday that two Sudanese brothers have been charged with operating a prolific hacking group that orchestrated tens of thousands of politically motivated cyberattacks against worldwide government agencies, Los Angeles' Cedars-Sinai Medical Center and companies including Microsoft, PayPal, Google and Netflix. 2 documents attached | Read full article » <https://www.law360.com/technology/articles/1890735?nl_pk=2bd720dd-746c-4744…> | Save to favorites » <https://www.law360.com/technology/articles/1890735?nl_pk=2bd720dd-746c-4744…>

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