On Thu, Jul 20, 2023, 6:36 PM Scott, Kathleen (DFS) < [email protected]> wrote:
> Dear Mr. Larson > > I am in receipt of your messages and conferring on a response > > Very truly yours, > > 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 > > [email protected] > > > > *www.dfs.ny.gov <http://www.dfs.ny.gov/>* > > > > > > > > > > > > *From:* Gunnar Larson <[email protected]> > *Sent:* Thursday, July 20, 2023 6:34 PM > *To:* Scott, Kathleen (DFS) <[email protected]> > *Cc:* [email protected]; Tomczak, Christine (DFS) < > [email protected]>; Harris, Adrienne A (DFS) < > [email protected]>; [email protected]; > dfs.sm.BankingComments <[email protected]> > *Subject:* Re: NY-DFS Proposed Guidance on Character and Fitness > (Extension Appeal) > > > > *ATTENTION: This email came from an external source. Do not open > attachments or click on links from unknown senders or unexpected emails.* > > > > > > 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 > > > > > >
