On Thu, Jul 20, 2023, 5:28 PM Gunnar Larson <[email protected]> wrote:
> > 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 >>>> >>>> >>>> >>>> >>>> >>>
