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Comment Letters
2008
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2008 Comment Letters

Letter to Treasury Department and IRS requesting clarification on Notice 2008 83 which provides guidance for the proper treatment of certain items of deductions or loss allowed after an ownership change to a corporation
10/31/08
Letter to FDIC on recordkeeping requirements for qualified financial contracts
10/30/08
Letter to OCC, Fed, FDIC, and OTS on the Deduction from Tier 1 Capital of Goodwill Net of Associated Deferred Tax Liability
10/28/08
Letter to IRS on Settlement Guidelines for Certain Structured Finance Transactions Referred to as ?Foreign Tax Credit Generators?
10/24/08
Letter to FDIC Requesting an Extension of Time to Respond to the Proposal Regarding Recordkeeping Requirements for Qualified Financial Contracts
9/23/08
Joint letter to Basel Committee on Banking Supervision from Wolfsberg Group Co-chairmen and TCH commenting on its consultative document "Due Diligence and Transparency Regarding Cover Payment Messages Related to Cross-Border Wire Transfers"
9/12/08
Letter to Center for Audit Quality responding to draft white paper "Application of Statement 114 to Residential Mortgage Loans Subject to Modification"
9/5/08
Letter to Financial Accounting Foundation on FASB?s Accounting Standards Codification Project
9/5/08
Letter to Treasury Department on possible regulations on interest expense disallowance rules under IR Code section 265(b)
8/20/08
Letter to IRS requesting an extension of time to respond to the invitation to participate in the LILO/SILO settlement initiative
8/13/08
Letter to FASB on proposed amendment to FAS 5 and 141(R) on Disclosure of Certain Loss Contingencies
8/7/08
Letter to Basel Committee on Banking Supervision commenting on Principles for Sound Liquidity Risk Management and Supervision
7/31/08
Joint letter to Senate Finance and House Ways and Means Committee in support of delaying the effective dates for new merchant payment card information reporting
7/15/08
Joint letter with ABA, ETA, and FSRound Table in support of the Crapo amendment to delay the effective dates for new merchant payment card information reporting
7/7/08
Letter to OFAC regarding guidance on entities owned by blocked persons
7/2/08
Letter to Fed requesting clarification of amendments to Regulation D regarding time deposit open accounts
6/24/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to Senate Finance Committee opposing the use of payment card reporting proposal as a revenue offset for any legislation
6/19/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to House Ways and Means Committee opposing the use of the payment card reporting proposal as a revenue offset for any legislation
6/18/08
Joint letter with the ABA and ABASA to FINRA on its proposal for supervision of persons who are dual employees of banks and broker dealers
6/13/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to House Small Business Committee opposing information reporting on payment card reimbursements to merchants
6/12/08
Letter to Fed on payment system risk policies and daylight overdraft posting rules
6/11/08
Joint letter with Council on State Taxation and numerous other organizations opposing the NCCUSL project to revise the Uniform Division of Income for Tax Purposes Act
5/28/08
Letter to Senate Finance Committee on information reporting on electronic payment mechanism reimbursements
4/30/08
Letter to IRS endorsing SIFMA ?s letter on mark to market tax accounting rules
4/23/08
Joint letter with ABA and FSR on proposed rules regarding processing of deposit accounts in a large bank failure
4/16/08
Joint letter with ABA, ETA, FSR, NAM, and US Chamber of Commerce opposing proposed legislation to require information reporting on payment card reimbursements and using it as a revenue offset for the Farm, Nutrition and Bio-energy Act (H.R. 2419)
4/16/08
Letter to FDIC on proposed rules regarding the processing of deposit accounts in a large bank failure
4/15/08
Letter to IRS on proposed guidance for tax information reporting for mortgage insurance premiums
3/27/08
Joint letter with ABA to OCC, Fed, FDIC, and OTS on regulatory reporting requirements relating to Basel II
2/25/08
Letter to Fed on proposed revisions to Form FR Y 9C
12/20/07
Joint letters with industry groups to the Treasury Department, State Department, and Commerce Department urging them to ask that the Solicitor General file an amicus brief supporting a petition for certiorari to the U.S. Supreme Court
12/14/07
Letter to Treasury Department and Fed on proposed regulations implementing the Unlawful Internet Gambling Enforcement Act of 2006
12/12/07
Letter to Treasury Department on review of regulatory structure to maintain the competitiveness of U.S. capital markets
12/6/07
Letter to OCC, Fed, FDIC, and OTS on revisions to Call Reports
11/13/07
Letter to Basel Committee on Banking Supervision from Wolfsberg Group Co-chairmen and TCH
10/19/07
Letter to FDIC on the implementation of documentation requirements outlined in the Interim Deposit Review Guide
9/28/07
Letter to the Center for Audit Quality on the draft account white papers, "Measurements of Fair Value in Illiquid (or Less Liquid) Markets" and "Consolidation of Commercial Paper Conduits."
9/24/07
Second joint letter with the ABA and ABASA to SEC and Fed responding to inquiries about Proposed Regulation R
8/9/07
Joint letter with the ABA and ABASA to SEC and Fed responding to inquiries about Proposed Regulation R
7/16/07
Letter to FASB requesting that FASB permit early adopters of SFAS 159 to make additional FVO elections because of the issuance of AICPA SOP 07-1
7/10/07
Letter to Senate Finance Committee staff on basis reporting of securities transactions
6/29/07
Letter to IRS on the proposed foreign tax credit regulations
6/28/07
Letter to SEC on proposed amendments to Financial Responsibility Rules for broker-dealers (Rule 15c3-3)
6/18/07
Request for changes in Form FR Y-9LP
6/15/07
Joint letter with the ABA and ABASA to SEC and Fed responding to letter from the National Association of Securities Dealers on Regulation R
6/7/07
Letter to Chairman and Ranking Minority Member of the Senate Committee on Finance requesting support for S. 636, ?Reduce Wasteful Tax Forms Act of 2007?
4/24/07
Letter to Fed and SEC on proposed Regulation R addressing push out provisions of Title II of the Gramm-Leach Bliley Act
3/30/07
Letter to Fed in response to questions about energy tolling arrangements
3/29/07
Letter to Fed and SEC requesting extension of time to comment on Regulation R proposals
3/26/07
Letter to OCC, Fed, FDIC, and OTS on regulatory reporting requirements relating to Basel II
3/26/07
Letter to FDIC on adjustment guidelines for deposit insurance assessment rates
3/23/07
Letter to Fed on intraday liquidity management and payment-system risk
3/12/07
Letter to OFAC requesting a general license for operation of Totten trust accounts
3/12/07
Joint letter with the ABA and Financial Services Roundtable on Cross-Border Electronic Funds Transfer Reporting System
3/5/07
Letter to IRS requesting an exclusion of certain section 988 transactions from reportable transactions requirements
3/5/07
Letter to FASB on proposed amendment to FAS 133 on Disclosures about Derivatives Instruments and Hedging Activities
3/2/07
Letter to Fed on its proposal to except small-dollar transactions from Regulation E terminal-receipt requirements
1/31/07
Letter to IRS on the Masking of taxpayer identification numbers
12/29/06
Letter to Fed on reporting requirements for changes in organizational structure (FR Y 10; FR Y-6)
11/13/06
Letter to IRS requesting mutual agreements with competent authorities of various countries to provide exemptions from withholding for foreign source dividends paid to pension funds
11/11/06
Letter to IRS on the proposed foreign tax credit regulations
10/2/06
Letter to FDIC on risk-based deposit insurance assessments
9/22/06
Letter to Fed on proposed amendment to payment system risk policy
9/22/06
Letter to FinCen supporting proposal to reduce or eliminate $3,000 threshold for travel and recordkeeping
9/8/06
Letter to AICPA and FASB on proposed SOP on accounting for investment companies
6/29/06
Letter to Fed, FDIC, OCC, OTS, and SEC on sound practices concerning elevated risk complex structured finance activities
6/15/06
Letter supporting Financial Services Regulatory Relief Act of 2006 and provision regarding push out rules
5/8/06
Letter to OFAC on Economic Sanctions Enforcement Procedures for Banking Institutions
4/25/06
Letter to FDIC on proposed rulemaking on preemption of certain state laws affecting interstate activities of state-chartered banks and their operating subsidiaries
4/3/06
Letter to Commercial Mortgage Securities Association on discretion of servicers in credit card securitizations
3/30/06
Letter to OCC, FRBNY, and FDIC requesting clarification on FR Y-9C, Schedule HC-S, and FFIEC 031, Schedule RC-S regarding asset sales and securitizations
3/29/06
Letter to Fed, FDIC, OCC, and OTS on Proposed Guidance on Nontraditional Mortgage Products
3/28/06
Letter to FDIC on determinations of deposit insurance coverage for deposits at large banks
3/27/06
Letter to AICPA on the proposed SOP on accounting for investments companies.
3/20/06
Letter to FinCEN requesting a 90-day extension of time to comply with the final rule under section 312 of the USA PATRIOT Act.
3/10/06
Joint letter with industry groups to FinCEN on enhanced due diligence for correspondent accounts under Section 312 of the USA PATRIOT Act.
3/6/06
Letter to Fed, FDIC, OCC, and OTS requesting extension of time to file comments on the Proposed Guidance on Nontraditional Mortgage Products
1/26/06
Letter to Fed on regulatory capital treatment of securities borrowing transactions
1/19/06
Letter to Fed,FDIC, OCC, and OTS on possible modifications to risk-based capital guidelines ("Basel I-A")
1/18/06
Letter to Fed, on proposed revisions to Form FR Y-9
12/27/05
Letter to Fed, OCC, and FDIC on regulatory capital treatment of securities borrowings transactions
12/5/05
Letter to IRS suggesting priorities for Revisions to Treasury Regulations Concerning Withholding and Information Reporting
10/31/05
Letter to OCC, Fed, and FDIC on revisions to Call Reports.
10/24/05
Letter to FASB on Proposed FASB Staff Position No. FAS 123(R)-b
10/4/05
Letter to FASB on Accounting for Uncertain Tax Positions, an Interpretation of FASB Statement No. 109
9/12/05
Letter to Fed on ROE Calculation for Private Sector Adjustment Factor (PSAF)
8/5/05
Joint letter with ABA to IRS on IRS policy for requesting tax accrual workpapers.
7/29/05
Letter to Fed, OCC, FDIC, and OTS on proposed framework for the classification of commercial credit exposure.
6/29/05
Letter to IRS on proposed withholding and information reporting regulations under IRS Code Sections 1441, 6049, and 6114
6/27/05
Letter to FASB and AICPA on proposed Statement of Position to clarify scope of the Investment Company Audit and Accounting Guide
6/21/05
Letter to OCC, Fed, and FDIC on revisions to Country Exposure(FFIEC 009 and 009a)
6/17/05
Letter to FASB and AICPA with presentation materials on Investment Company Audit Guide
5/31/05
Letter to Fed on its proposal to amend Reg CC to create rules governing remotely created checks.
5/3/05
Letter to Fed, OCC, FDIC, and OTS on leveraged lease accounting.
5/3/05
Letter to Treasury Department on taxation of sale-in/lease-out ("SILO") transactions involving qualified transportation property.
4/26/05
Letter to Federal Reserve, OCC, FDIC, and the OTS on Modernization of the Collection of Shared National Credit Data.
4/11/05
Letter to FASB on AICPA's proposed Statement of Position regarding accounting for investment companies.
3/7/05
Letter to Fed and OCC on leveraged lease accounting.
3/3/05
Letter to FASB on leveraged lease accounting.
2/18/05
Letter to OCC, Fed, FDIC, and OTS on internal ratings-based systems for retail credit risk for regulatory capital.
2/7/05
Joint letter with ABA to SEC regarding Regulation B and enclosing "Regulation B Principles" and "Why Conducting a Brokerage Business Inside the Bank is Not Feasible."
1/31/05
Letter to SEC enclosing "Why Conducting a Brokerage Business Inside the Bank is Not Feasible."
1/18/05
Letter to Fed on revisions to Forms FR Y-9C, FR Y-9LP, FR Y-11, and FR 2314.
12/27/04
Letter to Fed on proposed amendments to Regulation E.
11/29/04
Letter to FASB on FASB Staff Position on proposed effective date for EITF Issue 03-1-b regarding other-than-temporary impairment of investment securities
10/29/04
Letter to OCC, Fed, and FDIC on revisions to the Country Exposure Report (FFIEC 009) and the Country Exposure Information Report(FFIEC 009a)
10/18/04
Letter to FASB on FASB Staff Position on proposed effective date for EITF Issue 03-1-b regarding other-than-temporary impairment of investment securities
9/29/04
Letter to Fed on its proposal to revise the rating system for bank holding companies
9/28/04
Letter to Fed on proposal to amend Report of Derivatives Activity (FR 2436) and Report of Equity Investments in Nonfinancial Companies (FRY-12)
9/23/04
Letter to FinCEN on its proposal to impose special measures against First Merchant Bank OSH Ltd. and Infobank
9/23/04
2004 - 09/01- attachment
9/1/04
Letter to SEC on proposed Regulation B addressing the push-out provisions of Title II of the Gramm-Leach-Bliley Act. Also see attachment .
9/1/04
Letter to FinCEN on its proposal to impose a special measure against the Commercial Bank of Syria.
7/27/04
Letter to FRB on its proposal to amend policy statement on payment system risk.
7/27/04
Letter to FRB providing additional comments on proposed revisions to Regulation J
7/26/04
Joint letter with industry groups to FRB on proposed revisions to Regulation J
7/23/04
Letter to OCC, FRB, FDIC, OTS, and SEC on complex structured finance activities of financial institutions.
7/19/04
2004 - 07/09 - Annex 1
7/9/04
2004 - 07/09 - Related Letter
7/9/04
Letter to FRB on regulatory capital treatment of Trust Preferred Securities and limitations on restricted core capital elements. Also, Annex 1 & related letter .
7/9/04
Letter to OCC, FRB, FDIC, and OTS on Call Report change for "when issued securities."
6/30/04
Letter to IRS requesting elimination of employer identification number requirement for foreign grantor trusts with five or fewer owners.
6/25/04
Letter to IRS on applications for U.S. Residency Certification (Forms 6166 and 8802).
5/12/04
Letter to IRS on Industry Directive on Examination of Forms 1042
4/16/04
Second letter to OCC, FRB, FDIC, and OTS on the regulatory capital treatment of consolidated asset-backed commercial paper programs.
4/5/04
Letter to Federal Reserve Board on proposed amendments to Regulation CC to implement Check 21 Act
3/12/04
Letter to Internal Revenue Service on proposed Form 8858 for information returns regarding foreign disregarded entities.
3/1/04
Letter to Federal Reserve Board on proposed revisions of FR Y-9C reports
2/13/04
Letter to SEC on proposed alternative net capital requirements for broker-dealers
2/9/04
Letter to FinCEN on guidance requiring Suspicious Activity Report for any OFAC list match
2/6/04
Letter to FRB on regulatory capital treatment of trust preferred securities deconsolidated under FIN 46R
1/15/04
Letter to FRB and OCC on Clearing House proposal regarding regulatory capital treatment of securities fails to deliver
12/19/03
Letter to FRB, FDIC, OCC and OTS on implementing the New Basel Capital Accord in the United States
11/26/03
Letter to OCC, FRB, FDIC and OTS on the regulatory capital treatment of consolidated asset-backed commercial paper programs
11/21/03
Letter to Treasury Department on IRS's Coordinated Issue Paper on LILO transactions
11/21/03
Letter to OCC, FRB, FDIC and OTS on the regulatory capital treatment of consolidated asset-backed commercial paper programs
11/17/03
Joint letter with ABA to Basel Committee on Banking Supervision on consolidated know your customer risk management
11/3/03
Joint letter with ABA to FinCEN on the CIF exception to the travel rule
10/20/03
Joint letter with Electronic Payments Network L.L.C. to Treasury Department on proposal to amend regulations on the use of ACH system by federal agencies
10/20/03
Letter OCC, FRB, FDIC and OTS on reducing regulatory burden
10/20/03
Letter to FASB on proposed FASB Staff Letter to OCC, FRB, FDIC and OTS on proposed interagency guidance on identity theft
10/14/03
Letter to OCC on proposed preemption regulation
10/14/03
Letter to FASB on proposed FASB Staff Position (FSP) No. FIN 46-d regarding treatment of fees paid to decision makers and guarantors under FIN 46
10/10/03
Letter to Federal Reserve Board on proposed interpretation of the anti-tying restrictions of section 106 and related supervisory guidance
10/3/03
Letter to AICPA on proposed Statement of Position on the allowance for credit losses
9/19/03
Letter to Basel Committee on Banking Supervision on third consultative paper concerning New Basel Capital Accord
8/19/03
Letter to SEC on the role of credit rating agencies in the securities markets
7/31/03
Letter to Treasury Department on implementing the tax information reporting provision of the Jobs and Growth Tax Relief Reconciliation Act of 2003
7/29/03
2003 - 07/17 - Letter 1
Letter to California legislators on pending California legislation on tax shelters with related letters:Letter 1, Letter 2, Letter 3,
7/17/03
2003 - 07/17 - Letter 2
Letter to California legislators on pending California legislation on tax shelters with related letters:Letter 1, Letter 2, Letter 3,
7/17/03
2003 - 07/17 - Letter 3
Letter to California legislators on pending California legislation on tax shelters with related letters:Letter 1, Letter 2, Letter 3,
7/17/03
Letter to California legislators on pending California legislation on tax shelters with related letters: Letter 1, Letter 2, Letter 3,
7/17/03
Letter to Department of Homeland Security offering assistance in fight against terrorism
7/14/03
2003 - 06/23 - Brief
Letter to Treasury Department on Financial Management Service's proposed revisions to regulations on U.S. Treasury checks with related amicus brief attached
6/23/03
2003 - 06/23 - Letter to Treasury Department
Letter to Treasury Department on Financial Management Service's proposed revisions to regulations on U.S. Treasury checks with related amicus brief attached
6/23/03
Letter to FRB, FDIC, and OCC on proposal to extend the foreign branch report of condition
6/19/03
Letter to New Jersey Division of Taxation on regulations proposed under New Jersey's Business Tax Reform Act
6/3/03
Letter to the Public Company Accounting Oversight Board on audits of management assessment of internal controls under Section 404 of Sarbanes-Oxley Act
5/13/03
Letter to Chairmen and Ranking Members of tax-writing committees of Congress on the proposed codification of the economic substance doctrine and related penalty provisions in the CARE Act of 2003
5/9/03
Joint Letter with industry groups to Letter to FRB and OMB on proposed revisions to report on Section 23A transactions
5/5/03
Joint Letter with industry groups to FinCEN on proposed expiration of conditional exception to the travel rule for customer information file (CIF)
4/21/03
Letter to Federal Reserve Board on proposal to amend Regulation Y to permit bank holding companies to engage as principal in commodity derivatives trading activities
4/18/03
Letter to FRB, OCC, FDIC, and OTS requesting guidance on regulatory capital treatment of variable interest entities (VIEs) that are consolidated under FASB Interpretation No. 46
4/10/03
Letter to OCC on proposed preemption of Georgia Fair Lending Act
4/2/03
Letter to OFAC on proposed enforcement guidelines
3/31/03
Comment Letter - 2003 - 03/19 - Fed
Joint letter with industry groups to Federal Reserve Board, Senator Shelby, and Congressman Oxley opposing proposal to exempt cashier's checks, teller's checks, and money orders from coverage under Check 21 Act
3/19/03
Comment Letter - 2003 - 03/19 - Oxley
Joint letter with industry groups to Federal Reserve Board, Senator Shelby, and Congressman Oxley opposing proposal to exempt cashier's checks, teller's checks, and money orders from coverage under Check 21 Act
3/19/03
Comment Letter - 2003 - 03/19 - Shelby
Joint letter with industry groups to Federal Reserve Board, Senator Shelby, and Congressman Oxley opposing proposal to exempt cashier's checks, teller's checks, and money orders from coverage under Check 21 Act
3/19/03
Letter to Federal Reserve Board on expanding Fedwire operating hours
3/10/03
Letter to Treasury Department on implementation of USA PATRIOT Act
3/6/03
Letter to Federal Reserve Board on proposed revisions of instructions for required regulatory reports with related letters: Letter 1, Letter 2.
2/24/03
Letter to Federal Reserve Board on proposed revisions of instructions for required regulatory reports with related letters: Letter 1, Letter 2.
2/24/03
Letter to Federal Reserve Board on proposed revisions of instructions for required regulatory reports with related letters: Letter 1, Letter 2.
2/24/03
Joint letter with industry groups to SEC on proposal to revise Rule 10b-18 regarding stock repurchase programs during mergers and acquisitions
2/18/03
Letter to Federal Reserve Bank of New York on expansion of Treasury International Capital reports to include derivatives
2/7/03
Letter to Internal Revenue Service commenting on Revenue Ruling 2002-69 regarding lease in/lease out (LILO) transactions
1/31/03
Joint letter with industry groups to Treasury Department on designation of Nauru and Ukraine as countries of primary money laundering concerns under Section 311 of the USA PATRIOT Act
1/27/03
2003 - 01/13 - Assembly Speaker
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
2003 - 01/13 - Letter 1
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
2003 - 01/13 - Letter 2
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
2003 - 01/13 - Letter 3
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
2003 - 01/13 - Pataki
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
2003 - 01/13 - Senate Majority Leader
Letter to Governor Pataki, Assembly Speaker, Senate Majority Leader and staff ( letter 1, letter 2, letter 3) requesting that Article 32 of the Tax law and related financial holding company transition provisions be made permanent
1/13/03
Letter to OCC, FRB, and FDIC on revisions to Call Reports
1/7/03
Letter to OCC, FRB and FDIC on the proposal to require electronic submission of FFIEC 009 and 009a reports.
12/26/02
Letter to Treasury Department and OFAC on use of assets blocked under Iraqi sanctions to satisfy judgments under Section 201 of Terrorism Risk Insurance Act.
12/18/02
Letter to SEC on proposed rule for use of non-GAAP financial measures.
12/13/02
Letter to SEC on proposed "push out" regulations for certain securities dealer activities of banks as exceptions and exemptions from registration requirements under the Securities Exchange Act.
12/6/02
Letter to SEC on the proposed regulation to define "financial expert" under Section 407 of the Sarbanes-Oxley Act.
12/2/02
Letter to Fed on proposal to require electronic submission of FR Y-9 reports.
11/15/02
Joint letter with industry groups to House and Senate leadership on financial contract netting legislation.
11/12/02
Letter to Fed, OCC, SEC and New York State Banking Board on draft interagency white paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System.
10/29/02
Letter to OCC, FDIC, FinCEN, Fed, OTS and National Credit Union Administration on proposed regulations for anti-money laundering customer identification programs under Section 326 of the USA PATRIOT Act.
9/12/02
Letter to OCC, Fed, FDIC and OTS on a proposed call report schedule for subprime lending.
9/11/02
Letter to FASB on exposure draft for consolidation of certain special-purpose entities.
8/30/02
Comment Letter - 2002 - 08/22 - related Letter
8/22/02
Letter to FinCEN on the interim rules implementing section 312 of the USA PATRIOT Act. Also, related letter .
8/22/02
Letter to SEC on proposal for disclosure of critical accounting policies in management's discussion and analysis.
7/29/02
Letter to OFAC on proposal for public disclosure of information on civil penalties.
7/19/02
Joint letter with industry groups to SEC on exemptive relief from broker-dealer registration for credit unions offering sweep accounts.
7/18/02