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@xny.io>
Sent: Wednesday, June 28, 2023 12:05 AM
To: Scott, Kathleen (DFS) <Kathleen.Scott@dfs.ny.gov>
Cc: dfs.sm.BankingComments <BankingComments@dfs.ny.gov>; cypherpunks@cpunks.org
Subject: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
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Ms. Scott:
NY-DFS recently asked for public comment concerning "Proposed Guidance on Assessment of the Character and Fitness of Directors, Senior Officers, and Managers" mentioned here: https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidance_assessment_fitness.
xNY.io - Bank.org asks if the NY-DFS will extend deadline for public comment to August 5, 2023 from June 30, 2023.
As requested by NY-DFS, today we provide (in a separate attachment) evidence of any documented exceptions to compliance with the "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness."
We have collated 19 references comprising 205 highlights that touch on the five key areas below: https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO.
-Harassment and Discrimination Policies
-Conflict of Interest Policy
-Insider Trading Policy
-Records Management Policy
-Corporate Opportunity Policy
xNY.io - Bank.org is seeking NY-DFS' extension for public comment to August 5, 2023 so that the New York Banking community has time to complete Q2-23 earnings call disclosures.
As documented in the above 19 references, we feel extra time for public comment is warranted to ensure that xNY.io - Bank.org did not play a significant role or otherwise contribute in a meaningful way to the conduct that led to regulatory action or proceeding without ample notice.
Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness," can you kindly acknowledge that you have reviewed and understand our appeal seeking extension for public comment to August 5, 2023?
We hope to hear from you before June 30, 2023 given obvious factors.
Sending you the very best regards.
Thank you,
Gunnar
--
Gunnar Larson
xNY.io | Bank.org
MSc - Digital Currency
MBA - Entrepreneurship and Innovation (ip)
+1-917-580-8053
New York, New York 10001