NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)

[Gunnar Larson]

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 at 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 at xny.io>
> *Sent:* Wednesday, June 28, 2023 12:05 AM
> *To:* Scott, Kathleen (DFS) <Kathleen.Scott at dfs.ny.gov>
> *Cc:* dfs.sm.BankingComments <BankingComments at dfs.ny.gov>;
> cypherpunks at cpunks.org
> *Subject:* NY-DFS Proposed Guidance on Character and Fitness (Extension
> Appeal)
>
>
>
> You don't often get email from g at 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_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)
>
>
>
> G at xNY.io
>
> +1-917-580-8053
>
> New York, New York 10001
>
>
>
>
>
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