On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <[email protected]> wrote:
> 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 > > >
