Industry Issues: Recently Filed Comment Letters and Requests for Comment

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Overview ABA Issues Index ABA Regulatory Reform Center Grassroots Advocacy Comment Letters Letters to Congress Regulatory Proposals Testimonies Sites of Interest

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ABA Comment Letters

Year 2009
Year 2008
Year 2007
Year 2006

2010

ABA and ABASA Comment Letter on Brokers, Dealers and Investment Advisers, August 30, 2010
ABA Comment Letter to DOL on 408(b)(2) Interim Final Rule, August 27, 2010
ABA Comment Letter to SEC on Target Date Fund Issues and Bank Collective Funds, August 23, 2010
ABA Supports Modification of U.S. Currency to Accommodate the Blind, Offers Suggestions, August 18, 2010
ABA Comments on Proposal to Convert More Federal Benefits to Electronic Delivery, August 16, 2010
ABA and ABASA Comment Letter to SEC on Asset-Backed Securities August 3, 2010
ABA Expresses Concerns About Expansive HUD Interpretive Rule, July 26, 2010
ABA Comment Letter to FHFA on Housing GSEs Issue Guidance on PACE Loans, July 22, 2010
Letter to Treasury and HUD on Public Input on Reform of the Housing Finance System, July 21, 2010
Comment on FMS Proposal Amending the Automated Clearing House (ACH) System, July 13, 2010
FDIC Proposal to Amend the Pricing of Premiums for Large Banks, July 2, 2010
ABA and ABASA Comment Letter to FDIC on Securitization Safe Harbor, July 1, 2010
ABA Comments on Children's Online Privacy Protection (COPPA) Rule, June 29, 2010
ABA Comments on OTS proposal "Supplemental Overdraft Protection Guidance", June 28, 2010
ABA: FCC Should Confirm Current Guidance on Robocalls to Cell Phones, June 21, 2010
Comment Letter re: Permanently Exempt Smaller Companies from SOX 404(b), June 15, 2010
ABA Comments on Basel Consultative Document: Principles for Enhancing Corporate Governance, June 14, 2010
Comment on NCUA Proposal Amending FCU rule to Offer Short-term, Small loans, June 11, 2010
Comment on Templates for Safe, Low-cost Transactional and Basic Savings Accounts, June 7, 2010
ABA Opposes FCC Proposal Amending TCPA Regulations, Offers Suggestions, May 21, 2010
FDIC Interim Rule to Extend the Transaction Account Guarantee Program, May 19, 2010
ABA Comment Letter on CDFI Fund Statutory Review, May 7, 2010
ABA on NCUA proposed rule to revise the Regulatory Flexibility Program, May 6, 2010
ABA Comment Letter to IRS on Allowing ID Number Truncation, April 30, 2010
Joint Letter requests SOX Section 404(b) Exemption in Reg Reform Bill, April 22, 2010
ABA on Basel's Consultative Document regarding International Framework for liquidity risk measurement, April 15, 2010
ABA on Basel's Consultative Document regarding Strengthening the resilience of the banking sector, April 15, 2010
ABA addresses SBA regs preventing SBA guaranteed loans from being pledged as collateral, April 15, 2010
ABA Supports Reg Z Provision, Expresses Concerns on Other Aspects of Proposal, April 14, 2010
Joint Trade Letter on Restoring American Financial Stability Act, April 13, 2010
ABA Comments on Overdraft Proposals: Regulation E and Regulation DD, March 31, 2010
ABA Comment on Bank Enterprise Award (BEA) reporting form, March 24, 2010
ABA Says Reform Bill Doesn't End 'Too-Big-To-Fail', March 22, 2010
ABA Letter to Frank and Bachus on Small Business Lending Fund, March 12, 2010
ABA Letter to Dodd and Shelby on Small Business Lending Fund, March 12, 2010
Letter to FDIC requesting extension of transaction account guarantee program, March 12, 2010
ABA Letter on final rules amending the Home Ownership and Equity Protection Act, March 12, 2010
ABA Responds to Hud Proposed Rule of Safe Act, March 5, 2010
ABA Comment on Regulatory Requirements for Loan Participations Affected by FASB Statement No.166, March 3, 2010
ABA and ABASA to FINRA re: Registration and Qualification Requirements, March 1, 2010
Letter to NCUA on Proposal Amending Rule Regarding Corporate Credit Unions, February 23, 2010
ABA and ABASA to FDIC re: Securitization, February 22, 2010
Letter to NCUA on Chartering and Field of Membership for Credit Unions, February 19, 2010
Letter to FDIC on Employee Compensation Criteria in Risk Assessment System, February 17, 2010
ABA Suggests Changes to Proposed Merchant Card Reporting Regulations, January 25, 2010
ABA: Provide More Info in Call Report on Assets Covered by FDIC, January 22, 2010
ABA Thrift Financial Report Comment Letter, January 22, 2010
ABA: NACHA Met its Intended Goal in the Newly Reorganized ACH Rules, January 12, 2010

ABA Comments on HUD's FHA Reform Proposal, December 30, 2009
ABA on Proposed Changes to Closed-End Mortgage Disclosures, December 23, 2009
ABA on Implementing the Gift Card Provisions of Credit CARD Act, December 21, 2009
ABA Concerns About Proposed Changes for HELOC Disclosures, December 18, 2009
ABA Comments on FinCEN Proposal to Expand Access to Bank Data, December 16, 2009
ABA Letter: Encouraging the FHFA to Complete the Process of Converting all 12 FHLBs to the New Capital Structure, December 8, 2009
ABA Comment on Currency Transaction Report, FinCEN Form 104, December 1, 2009
ABA Comment on Proposed Sound Incentive Compensation Policies, November 25, 2009
ABA Comment on expansion of generic top-level Internet domains, November 22, 2009
ABA Suggests Improvements to Fed's Credit Card Rules, November 20, 2009
ABA Suggests Changes to Proposed BHC Reporting Form Revisions, November 20, 2009
Joint letter in support of the Perlmutter-Lucas amendment to the FSIA November 16, 2009
ABA on Derivatives and Hedging, Scope Exception to ED, November 12, 2009
ABA Comment Letter on Reg Z Impact, November 4, 2009
Comment on Proposal re: Board of Directors of the FHLB System, November 4, 2009
FDIC Proposal on Prepaid Assessments, October 28, 2009
FTC Proposal re: Telemarketing Sales Rule, October 26, 2009
Regulatory Capital proposal in response to FAS 166 and 167, October 15, 2009
Housing and Economic Recovery Act Section 1217 Study,October 14, 2009
ABA Letter to SEC Re RIA Political Contributions, October 6, 2009
ABA Letter to IRS Re FBAR, October 6, 2009
Letter to FASB on Improving Disclosures about Fair Value Measurements, October 6, 2009
Letter to Treasury on New Markets Tax Credit Program Application, October 2, 2009
Regulatory Capital Limits on Deferred Tax Assets, September 25, 2009
- Deferred Tax Assets Historical Perspective Tools
Letter to FHFA to Serve Underserved Markets for Fannie and Freddie, September 18, 2009
ABA Comment Letter to IASB on Classification and Measurement, September 14, 2009
ABA Supports FinCEN MSB Proposal, Offers Suggestions, September 9, 2009
ABA Comment Letter to SEC on Money Market Fund Reform, September 8, 2009
ABA on Consolidation of Asset-Backed Commercial Paper Programs, September 2, 2009
ABA Comment on FinCEN Proposal Regarding Mutual Funds, September 2, 2009
ABA Comment Letter on IASB RFI on Expected Cash Flows, September 1, 2009
ABA on Guidelines for Furnishers of Info to Consumer Reporting Agencies, August 28, 2009
ABA on Possible AML Program for Non-bank Mortgage Lenders, August 20, 2009
ABA Comment Letter on Proxy Access Proposal, August 17, 2009
ABA on TARP Standards for Compensation and Corporate Governance, August 14, 2009
ABA Comment on Goodwill Net of Tax GAAP Issue, August 7, 2009
ABA Comment on Proposed rule on GSE Executive Compensation, August 4, 2009
ABA Comment on the Interagency Proposal to Revise CRA, July 30, 2009
ABA Comment on FTC's Mortgage Acts and Practices Rulemaking, July 29, 2009
Extension of the FDIC Transaction Account Guarantee Program, July 29, 2009
Letter to SEC on Custody of Funds Proposal, July 28, 2009
Letter to FTC on Mortgage Assistance Relief Services, July 15, 2009
ABA on Residential Mortgage Loans, Making Home Affordable Program, July 13, 2009
NACHA Proposal re: Direct Access Registration, July 10, 2009
Interagency SAFE Act Rules that would Require Loan Originators to Register with a National Database. July 9, 2009
ABA Comment Letter to FASB regarding 157-g, July 7, 2009
Comment Letter on Amendments to Regulation SHO, July, 1, 2009
ABA on Regulatory Capital Adjustments in Response to FASB Sales and Consolidation, June 5, 2009
ABA and ABASA Urge FinCEN to Change Proposed SAR Guidance, June 5, 2009
ABA Urges the Agencies to Abandon Reg AA Proposal, June 4, 2009
Changes to Reg Z, June 4, 2009
NACHA Customer Service Telephone Number RTI, May 28, 2009
ABA and CBA Comment on Regulation Z, HEOA, May 26, 2009
FHFA interim final rule on Capital Classifications for the Federal Home Loan Banks, May 18, 2009
IBFed Response to BCBS and IADI on Core Principles for Effective Deposit Insurance Systems, May 15, 2009
Letter to FinCEN on CIP Proposal, May 12, 2009
Regulatory Capital Limits on Deferred Tax Assets (DTAs), May 7, 2009
RESPA Withdrawal of Required Use Provision, April 9, 2009
FDIC Interim Rule to Extend the TLGP Debt Guarantee Program, April 7, 2009
FDIC Proposal: Deposit Interest Rate Restrictions for Banks Not "Well Capitalized," April 6, 2009
National Credit Union Administration Comment Letter, April 3, 2009
ABA Comments on Porting under the Telephone Consumer Protection Act, April 2, 2009
FDIC Interim Rule on Assessments, April 1, 2009
Reg E, Electronic Fund Transfers, March 27, 2009
FDIC Interim Rule Modifying the TLGP Debt Guarantee Program, March 19, 2009
Basel Committee Consultative Document on Stress Testing, March 13, 2009
ABA Comment on CRA Interagency Q&A, March 9, 2009
FinCEN Proposal on Regulatory Simplification, March 6, 2009
HUD Proposal on Secure and Fair Enforcement for Mortgage Licensing Act, March 5, 2009
IRS Proposal on Cost Basis Reporting Guidance, March 3, 2009
Clear Guidelines Needed on BEA Program, ABA says March 2, 2009
Fed Proposal on Reserve Requirements of Depository Institutions, February 24, 2009
Fed Proposal on Reg Z (TILA), February 9, 2009
ABA Supports NACHA Proposal on ACH Payments, offers suggestions, January 9, 2009

2008

FDIC Proposal on Assessments, December 17, 2008
Amendments to Regulation SHO, December 16, 2008
Mortgage Servicing Accounts, December 15, 2008
ABA Comment Letter Follow-up re: Executive Compensation, December 12, 2008
Thrift Financial Report Schedules, December 1, 2008
FDIC Deposit Insurance Regulations; Revocable Trust Accounts, December 1, 2008
Treatment of Certain Claims on, or Guaranteed By Fannie and Freddie, November 26, 2008
Changes to Call Report , November 24, 2008
Treatment of Perpetual Preferred Stock, November 21, 2008
Reserve Requirements of Depository Institutions, November 21, 2008
Continuation of FHA Secure Advocacy Letter, November 19, 2008
Troubled Assets Relief Program (TARP), November 19, 2008
ABA Letter to FDIC Proposal on raisingAssessment Rates in 2009, November 17, 2008
SEC - Fair Value - SEC Study, November 13, 2008
ABA Letter to FASB on OTTI, November 13, 2008
FDIC Temporary Liquidity Guarantee Program, November 13, 2008
FASB - Fair Value - Delay Implementation FASB 157 and 141R , November 12, 2008
NACHA Proposal re: Authorizations and Returns, November 7, 2008
Economic Sanctions Enforcement Guidelines, November 05, 2008
Leverage Ratio Exemption, October 31, 2008
Money Market Mutual Funds, October 31, 2008
Reg W: Exception for Certain Securities Financing Transactions, October 31, 2008
Capital Adequacy Guidelines; Deduction of Goodwill Net of Deferred Tax Liability, October 30, 2008
Guarantee Program for Troubled Assets, October 28, 2008
Standardized Approach to Determine Risk-Based Capital, October 27, 2008
IRS on Filing Extension Proposal, September 29, 2008
Recordkeeping Requirements for Qualified Financial Contracts Rule, September 26, 2008
Basel Committee on Cross-border Wire Transfers, September 15, 2008
FDIC Interim Rule on Processing Deposit Accounts in a Bank Failure, September 15, 2008
DOL's Fee Disclosures for Plan Participants Proposal, September 12, 2008
SEC and Board Proposal re: Bank Repurchase, September 8, 2008
OCC Proposal re: Community Development Projects, September 5, 2008
ABA Joint Industry Comment Letter on Regulation C (HMDA), August 29, 2008
ABA: Risk-Based Pricing Notices Proposal 'Workable, Flexible', August 19, 2008
ABA Letter to ADA Proposal on Nondiscrimination on the Basis of Disability by Public Accommodations, August 14, 2008
NCUA, Member Business Loans, August 13, 2008
UDAP Credit Card Practices, August 4, 2008
Joint RESPA Letter to OMB, July 31, 2008
Joint RESPA Letter to HUD, July 31, 2008
UDAP Overdraft Practices Proposal, July 30, 2008
FDIC re: CDARS , July 29, 2008
Implementation Concerns with the IRS' Automatic Contribution Arrangements Proposal, July 25, 2008
FDIC's Financial Education Programs, July 23, 2008
FDIC National Unbanked and Underbanked Household Survey, July 18, 2008
Regulation Z, Truth in Lending, July 18, 2008
Regulation DD Truth in Savings Proposal, July 18, 2008
NCUA Low Income Definition, July 2, 2008
NCUA and CUSO, July 2, 2008
ABA/ABASA Letter on Covered Bond Policy Statement, June 23, 2008
ABA/ABASA Weigh In on FINRA Exemption, June 13, 2008
ABA Urges HUD to Withdraw RESPA Proposal, June 12, 2008
Payment Systems Risk and Daylight Overdraft Rules, June 4, 2008
ABA Asks for Reg DD Extension, May 27, 2008
FDIC on Assessment Dividends, May 23, 2008
Flood Insurance Interagency Q&A, May 20, 2008
Home Valuation Code of Conduct, April 30, 2008
Joint letter to OFHEO re: Home Valuation Code, April 30, 2008
FDIC on Information Collection and Proposed Surveys in Support of AEI Initiatives, April 25, 2008
Joint ABA letter: Processing of Deposit Accounts in a Bank Failure, April 16, 2008
ABA HOEPA comment letter (Truth in Lending), April 8, 2008
Reserve Requirements of Depository Institutions Proposal, March 27, 2008
OFHEO Proposal to Amend its Risk-Based Capital Regulation, March 4, 2008
Comment on Proposed Reporting Requirements for Basel II Advanced Approaches Banks, February 25, 2008
Letter to the Committee of European Banking Supervisors on its Hybrid Capital Consultation Paper, February 22, 2008
Agencies' Proposal Intended to Improve Information on Credit Reports, February 11, 2008
FDIC Proposed Annual Audit Changes, February 4, 2008
FDIC Draft Survey First Should Identify Obstacles of Unbanked, January 29, 2008
SEC Concept Release re: State Sponsors of Terrorism Tool, January 22, 2008
Proposal to Convert from the Thrift Financial Report to the Call Report, January 14, 2008

ABA Comment letter on Anti-Internet Gambling Rule, December 12, 2007
ABA Comment letter on Allowing US fliers to use IFRS, November 27, 2007
ABA Comment letter on Garnishment of Federal Benefit Payments, November 27, 2007
Proposed FDIC Survey of Large Bank Insured Deposit Programs, November 21, 2007
Comment on Regulatory Structure Review, November 20, 2007
FDIC Advance Proposal on Assessment Dividends, November 19, 2007
ABA, ACB Say No Need to Issue More UDAP Regs, November 6, 2007
IRS Type III SOs Proposal, October 31, 2007
IRS Trust Fees Proposal, October 25, 2007
Joint Comment Letter on Proposed Amendments to Regulation Z, October 12, 2007
ABA Comment on Money Laundering Risk System, October 5, 2007
Joint ABA-ACB Comment Letter to SEC Re Shareholder Proposals, October 2, 2007
ABA Comment letter on Elimination of IFRS to GAAP Reconciliation 21, September, 2007
Elimination of IFRS to GAAP Reconciliation, September 21, 2007
Letter to FASB on Proposed DIG E23, September 21, 2007
Letter to FASB on Accounting for Transfers of Financial Assets and Repurchase Financing Transactions, September 19, 2007
Proposed Revisions to the CRA Q&A, September 10, 2007
FTC Proposal on SSN Use in the Private Sector, September 5, 2007
OCC's Regulatory Review Amendments, September 5, 2007
Optional Charter Provisions in MHC Structures, August 27, 2007
Federal Reserve Proposal on Issues Raised in the HOEPA Hearing, August 15, 2007
SEC and FRB Proposal on Reg R, August 9, 2007
Letter to House Ways and Means Committee re: Type III Supporting Organizations, July 31, 2007
OCC Proposal on Special Lending Limits, July 9, 2007
Prohibited Service at Savings and Loan Holding Companies, July 6, 2007
Letter to the Senate Finance Committee on Basis Reporting, June 29, 2007
Federal Reserve Propoal on Proposed Changes to Regulation B, June 29, 2007
Federal Reserve Proposal on Changes to Regulation E, June 29, 2007
Federal Reserve Proposal on Changes to Regulation DD, June 29, 2007
Federal Reserve Proposal on Changes to Regulation Z, June 29, 2007
ABASA Comment to SEC on Amendments to Broker-Dealer Financial Responsibility Rules, June 18, 2007
DoD Proposed Limitations on Terms of Consumer Credit to Service Members and Dependents, June 11, 2007
OTS Proposed Revision of the Thrift Holding Company Rating System, June 8, 2007
FDIC-Fed-OCC-OTS Proposed Basel II Supervisory Guidance, May 29, 2007
ABA Supports Effort Reflected in Proposed Model Privacy Form, May 25, 2007
ABA Supports Proposed Expanded Exam Cycle for Small Depository Institutions, May 11, 2007
ABA Expresses Concerns on the Proposed Subprime Mortgage Lending Notice, May 8, 2007
OTS Proposal on Permissible Activities of S&L Holding Companies, April 25, 2007
IRS' Proposal on Section 509(a), April 13, 2007
Regulation R Proposal, March 27, 2007
FDIC-Fed-OCC-OTS Proposal on Basel IA Risk-Based Capital Rule, March 26, 2007
ABASA Joint Comment Letter on Regulation R Proposal March 26, 2007
FDIC-Fed-OCC-OTS Proposal on Basel II Risk-Based Capital Rule, March 23, 2007
ABA/ACB/FSR on Large Bank FDIC Assessment Adjustments, March 23, 2007
Large-Bank Deposit Insurance Determination Modernization Proposal, March 13, 2007
SEC Proposal on Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles; Accredited Investors in Certain Private Investment Vehicles, March 9, 2007
Study of Overdraft Protection Programs, March 9, 2007
ABA Requests Guidance Regarding Masking of Social Security Numbers and Taxpayer Identification Numbers on Documents Mailed to Taxpayers, February 12, 2007
ABA on Proposed Principles for Supervisory Review of Model Validation, February 26, 2007
Interim Rule Revising Reg L, Management Interlocks, February 12, 2007
SEC Proposal on Foreign Issuer Deregistration, February 12, 2007
FDIC Propsal on Small Loan Guidelines, February 1, 2007
Letter on Prohibited Transaction Exemption for the Provision of Investment Advice to IRA holders, January 30, 2007
ABA Makes Suggestions on Talent Amendment ("Payday Law"), January 23, 2007
ABA Says OTS' Proposed CRA Reg Alignment 'Unwarranted', January 23, 2007
Modification of the Market Risk Capital Rule, January 23, 2007
ABA Joint Talent Amendment Letter to DOD, January 5, 2007

2006

Letter to IRS on Regulation Regarding Capital Asset Exclusion for Accounts and Notes Receivable, December 21, 2006
Letter to FASB on Embedded Derivatives Issue, December 8, 2006
Default Investment Regulation, November 14, 2006
Draft Affiliate Sharing, November 7, 2006
Comments to SEC on Executive Compensation Disclosure, October 23, 2006
Comments to FDIC on Industrial Loan Companies and Industrial Banks, October 10, 2006
Impact of SFAS 155 on Securitizations, October 3, 2006
Extension of CTR Collection, September 25, 2006
FDIC Proposal on Risk-Based Premiums and a Base Assessment Schedule, September 22, 2006
FDIC Proposal to set the Designated Reserve Ratio of the Deposit Insurance Fund, September 21, 2006
Proposed Revision of Annual Information Return/Reports (Form 5500), September 19, 2006
SEC's Concept Release Concerning Management's Reports on Internal Control Over Financial Reporting, September 18, 2006
Advertisement of Membership, September 15, 2006
ID Theft Red Flags and Address Discrepancies under the FACT Act, September 14, 2006
Section 404 Extension for Non-Accelerated Filers, September 14, 2006
Reserve Requirements of Depository Institutions, September 13, 2006
Stock Benefit Plans in Mutual-to-Stock Conversions and Mutual Holding Company, September 11, 2006
Conversion of Insured Credit Unions to Mutual Savings Banks, August 28, 2006
Fed, FinCEN Considering Changing Reporting Threshold, August 21, 2006
FDIRA FDIC Assessment Credits, August 15, 2006
FDIRA FDIC Assessment System, August 15, 2006
FDIRA FDIC Dividend Requirements, August 14, 2006
CBET letter to Treasury Secretary Paulson, August 2, 2006
Comment Letter on MSBs, July 7, 2006
Thrift Financial Reports Revisions, June 27, 2006
UTP Re-Exposure Requests, June 23, 2006
Proposed Statement of Financial Accounting Standards, June 15, 2006
Proposed Interagency Statement on Sound Practices Concerning Complex Structured Finance Activities, June 15, 2006
Home Depot's Change in Bank Control Notice, June 6, 2006
Effect of FDIRA on Call Reports, May 22, 2006
Interim Rule Revising Deposit Insurance Regulations, May 22, 2006
Response To FinCEN Cross Border Transfer Survey, April 21, 2006
Suggested Improvements to SAR-DI, April 18, 2006
Letter to FASB on Fair Value Option, April 18, 2006
Mutual Fund Redemption Fees (22c-2), April 14, 2006
Executive Compensation and Related Party Disclosure, April 14, 2006
EGRPRA Burden Reduction: Prompt Corrective Action and Disclosure and Reporting of CRA-Related Agreements, April 3, 2006
Interagency Guidance on Concentrations in Commercial Real Estate, March 30, 2006
SEC Small Business Advisory Committee, April 3, 2006
Proposed Guidance on Nontraditional Mortgages, March 29, 2006
Proposed Amendments To NCUA "Underserved" Expansion Rules, March 27, 2006
Economic Sanctions Enforcement Procedures for Banking Institutions, March 13, 2006
Reg E Payroll Card Proposal, (due March 13; filed February 27, 2006)
ANPR on Revising Domestic Capital Adequacy Guidelines, January 18, 2006
Proposed Revisions to Community Reinvestment Act Questions and Answers, January 9, 2006
ABA Urges OCC to Make ML Risk Project Voluntary, January 9, 2006

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