Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
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@dfs.ny.gov> wrote:
Dear Mr. Larson,
The guidance <https://www.dfs.ny.gov/industry_guidance/industry_letters/il20240122_guidance_on_assessment> 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@dfs.ny.gov
*www.dfs.ny.gov <http://www.dfs.ny.gov/>*
*From:* Gunnar Larson <g@xny.io> *Sent:* Thursday, October 17, 2024 12:02 PM *To:* Scott, Kathleen (DFS) <Kathleen.Scott@dfs.ny.gov> *Cc:* cypherpunks@cpunks.org; Tomczak, Christine (DFS) < christine.tomczak@dfs.ny.gov>; dfs.sm.BankingComments < BankingComments@dfs.ny.gov>; Dean, Peter C (DFS) <Peter.Dean@dfs.ny.gov>; Reader, Shaun <sreader@curtis.com>; cypherpunks < cypherpunks@lists.cpunks.org> *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
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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@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@xny.io> *Sent:* Sunday, July 2, 2023 6:38 AM *To:* Scott, Kathleen (DFS) <Kathleen.Scott@dfs.ny.gov> *Cc:* cypherpunks@cpunks.org; Tomczak, Christine (DFS) < christine.tomczak@dfs.ny.gov>; Harris, Adrienne A (DFS) < Adrienne.Harris@dfs.ny.gov>; letitia.james@ag.ny.gov; dfs.sm.BankingComments <BankingComments@dfs.ny.gov> *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
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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_guidanc... .
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-talks... .
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@xNY.io
+1-917-580-8053
New York, New York 10001
On Fri, Jun 30, 2023, 7:02 PM Gunnar Larson <g@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@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@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_guidanc... .
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@xNY.io
+1-917-580-8053
New York, New York 10001
participants (1)
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Gunnar Larson