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Comment Letters

November 26, 2012 DFS' Comment Letter on the FHFA's Proposed State-Level Guarantee Fee Pricing
October 22, 2012 DFS' Comment Letter on the Proposed Basel III Bank Capital Rules

January 13, 2012

Department's Response to the Financial Accounting Foundation's Plan to Establish the Private Company Standards Improvement Council

2011 Comment Letters


July 29, 2011

Department's Response to the Securities and Exchange Commission's Work Plan on Incorporating International Financial Reporting Standards into the U.S. Financial Reporting System
June 27, 2011 Department's Response to the Proposed Rules of the Office of the Comptroller of the Currency Regarding Preemption of State Consumer Financial Protection Laws
April 21, 2011 Department's Response to FASB Discussion Paper on IASB's Hedge Accounting Proposal
April 15, 2011 Department's Response to FinCEN's Proposal to Reduce Direct State Access to Bank Secrecy Act Data through the Currency and Banking Reporting System (CBRS)
March 30, 2011 Department's Response to FASB/IASB Proposal on Impairment of Financial Instruments

2010 Comment Letters


September 29, 2010

Department's Response to FASB Proposal on Financial Instruments

August 20, 2010

Banking Department’s Response to Potential Revisions to the Community Reinvestment Act (CRA) Regulation, OCC Docket Number OCC-2010-0011; FRB Docket Number R-1386; FDIC RIN 3064-AD60; and OTS Docket Number OTS-2010-0019

August 6, 2010

Banking Department's Response to Potential Revisions to the Federal Reserve Board’s Regulation C Which Implements the Home Mortgage Disclosure Act (HMDA). Docket Number OP-1388

July 23, 2010

Banking Department's Response to Potential Revisions to the Community Reinvestment Act’s (CRA) Implementing Regulations, OCC Docket Number OCC-2010-10; FRB Docket Number R-1387; FDIC RIN 3064-AD60; and OTS-2010-0017

June 18, 2010

Banking Department's Response to Treasury's Proposed Rule on Garnishment of Bank Accounts Containing Federal Benefit Payments, RIN Nos. 3206-AM17, 3220-AB63, 0960-AH18, 1505-AC20 & 2900-AN67

June 4, 2010

Banking Department's Response to the FDIC's Safe Account Template

February 25, 2010

Banking Department's Comment Letter on Docket No. FR-5271-P-01-SAFE Mortgage Licensing Act; HUD Responsibilities under the SAFE Act

February 12, 2010

Department's Response to FASB Proposal on Loan Modifications


2009 Comment Letters


April 17, 2009

Department's Response to the Securities and Exchange Commission's Proposed Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by U.S. Issuers

March 31, 2009

Department's Response to the Financial Crisis Advisory Group


2008 Comment Letters


November 13, 2008

Department's Response to the Financial Accounting Standards Board's Proposal to Amend FASB Statement No. 140, "Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities"

November 13, 2008

Department's Response to the Financial Accounting Standards Board's Proposal to Amend FASB Interpretation No. 46(R), "Consolidation of Variable Interest Entities"

October 9, 2008

Department's Response to the Financial Accounting Standards Board's Proposal to Amend FASB Statement No. 157, "Fair Value Measurements"

September 19, 2008

Department's Response to the Financial Accounting Standards Board's Invitation to Comment and the International Accounting Standards Board's Discussion Paper on Reducing Complexity in Reporting Financial Instruments

August 8, 2008

Department's Response to the Financial Accounting Standards Board's Exposure Draft on Accounting for Hedging Activities


2007 Comment Letters


November 14, 2007

Department's Response to the Securities and Exchange Commission's Concept Release on Allowing U.S. Issuers To Prepare Financial Statements in Accordance With International Financial Reporting Standards

March 1, 2007

Department's Response to the Financial Accounting Standards Board’s Exposure Draft - Disclosures about Derivative Instruments and Hedging Activities


2006 and Earlier Comment Letters


May 8, 2006

Banking Department Comment Letter to FinCEN on the Advanced Notice of Proposed Rulemaking regarding Providing Banking Services to Money Services Businesses

August 6, 2004

Letter from Superintendent Taylor to Federal Banking Regulators Regarding the Proposed Guidance on Overdraft Protection Programs

March 24, 2004

Letter From Superintendent Taylor to Financial Services Committee Chairman Oxley Calling for Congressional Action on OCC Preemption

December 1, 2003

Department's Comment Letter on Proposal to Amend FASB Interpretation No. 46, "Consolidation of Variable Interest Entities"

November 3, 2003

Banking Department Comments on the Advance Notice of Proposed Rulemaking Issued by the Federal Bank Supervisory Agencies Concerning the U.S. Implementation of the New Basel Capital Accord

October 1, 2003

Banking Department Comment Letter to the Office of the Comptroller of the Currency Regarding the Notice of Proposed Rulemaking No. 03-16 Pertaining to Federal Preemption of State Anti-Predatory Lending Laws

July 30, 2003 Banking Department issues comments on the Financial Accounting Standards Board's exposure draft, Qualifying Special-Purpose Entities and Isolation of Transferred Assets