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2008
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2007
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2006
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2005
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2004
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2003
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2002
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2001
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2000
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2004 Comment Letters
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Letter to Fed on revisions to Forms FR Y-9C, FR Y-9LP, FR Y-11, and FR 2314.
12/27/04
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Letter to Fed on proposed amendments to Regulation E.
11/29/04
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Letter to FASB on FASB Staff Position on proposed effective date for EITF Issue 03-1-b regarding other-than-temporary impairment of investment securities
10/29/04
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Letter to OCC, Fed, and FDIC on revisions to the Country Exposure Report (FFIEC 009) and the Country Exposure Information Report(FFIEC 009a)
10/18/04
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Letter to FASB on FASB Staff Position on proposed effective date for EITF Issue 03-1-b regarding other-than-temporary impairment of investment securities
9/29/04
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Letter to Fed on its proposal to revise the rating system for bank holding companies
9/28/04
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Letter to Fed on proposal to amend Report of Derivatives Activity (FR 2436) and Report of Equity Investments in Nonfinancial Companies (FRY-12)
9/23/04
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Letter to FinCEN on its proposal to impose special measures against First Merchant Bank OSH Ltd. and Infobank
9/23/04
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Letter to SEC on proposed Regulation B addressing the push-out provisions of Title II of the Gramm-Leach-Bliley Act. Also see attachment .
9/1/04
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2004 - 09/01- attachment
9/1/04
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Letter to FRB on its proposal to amend policy statement on payment system risk.
7/27/04
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Letter to FinCEN on its proposal to impose a special measure against the Commercial Bank of Syria.
7/27/04
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Letter to FRB providing additional comments on proposed revisions to Regulation J
7/26/04
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Joint letter with industry groups to FRB on proposed revisions to Regulation J
7/23/04
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Letter to OCC, FRB, FDIC, OTS, and SEC on complex structured finance activities of financial institutions.
7/19/04
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Letter to FRB on regulatory capital treatment of Trust Preferred Securities and limitations on restricted core capital elements. Also, Annex 1 & related letter .
7/9/04
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2004 - 07/09 - Annex 1
7/9/04
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2004 - 07/09 - Related Letter
7/9/04
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Letter to OCC, FRB, FDIC, and OTS on Call Report change for "when issued securities."
6/30/04
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Letter to IRS requesting elimination of employer identification number requirement for foreign grantor trusts with five or fewer owners.
6/25/04
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Letter to IRS on applications for U.S. Residency Certification (Forms 6166 and 8802).
5/12/04
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Letter to IRS on Industry Directive on Examination of Forms 1042
4/16/04
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Second letter to OCC, FRB, FDIC, and OTS on the regulatory capital treatment of consolidated asset-backed commercial paper programs.
4/5/04
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Letter to Federal Reserve Board on proposed amendments to Regulation CC to implement Check 21 Act
3/12/04
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Letter to Internal Revenue Service on proposed Form 8858 for information returns regarding foreign disregarded entities.
3/1/04
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Letter to Federal Reserve Board on proposed revisions of FR Y-9C reports
2/13/04
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Letter to SEC on proposed alternative net capital requirements for broker-dealers
2/9/04
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Letter to FinCEN on guidance requiring Suspicious Activity Report for any OFAC list match
2/6/04
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Letter to FRB on regulatory capital treatment of trust preferred securities deconsolidated under FIN 46R
1/15/04
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