On Thu, Jul 20, 2023, 6:39 PM Gunnar Larson <[email protected]> wrote:
> > 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 >> >> >> >> >> >>
