On Sun, Jul 2, 2023, 6:38 AM Gunnar Larson <[email protected]> wrote:
> 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_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 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-to-exit-apple-partnership-wsj-says > . > > 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) > > [email protected] > +1-917-580-8053 > New York, New York 10001 > > On Fri, Jun 30, 2023, 7:02 PM Gunnar Larson <[email protected]> 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) < >> [email protected]> 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 <[email protected]> >>> *Sent:* Wednesday, June 28, 2023 12:05 AM >>> *To:* Scott, Kathleen (DFS) <[email protected]> >>> *Cc:* dfs.sm.BankingComments <[email protected]>; >>> [email protected] >>> *Subject:* NY-DFS Proposed Guidance on Character and Fitness (Extension >>> Appeal) >>> >>> >>> >>> You don't often get email from [email protected]. 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) >>> >>> >>> >>> [email protected] >>> >>> +1-917-580-8053 >>> >>> New York, New York 10001 >>> >>> >>> >>> >>> >>
