Home > Advocacy > Comment Letters Print Twitter Facebook LinkedIn Google Email Add to Favorites ABA Comment Letters Page ContentYear: 2016 | 2015 | 2014 | 2013 | 2012 | 2011 | 2010 For comment letters filed before 2010, check our Archives. Dodd-Frank Act developments are tagged . 2016 Letter to FFIEC on the Proposal to Revise the Uniform Interagency Consumer Compliance Rating System - June 29, 2016FDIC Proposal on Recordkeeping for Timely Deposit Insurance Determination - June 27, 2016ABA Letter to NCUA RE: FCU Occupancy, Planning and Disposal of Acquired and Abandoned Premises - June 27, 2016ABA Letter to Bob Storch on the Reporting of Equity Securities - June 20, 2016ABA/TCH response to a Basel Committee proposal on Pillar 3 Disclosures - June 10, 2016Joint Comment Letter to FCC on the Telephone Consumer Protection Act - June 6, 2016Joint Comment Letter to FRB re Single Counterparty Credit Limits for Large Banking Organizations - June 3, 2016ABA Comment Letter-Basel Operational Risk Capital Proposal - June 2, 2016ABA Comment Letter to IRS Re Basis Reporting By Executors Proposal - June 1, 2016ABA Comment Letter to OCC re Innovation Paper - May 31, 2016Comments-of- ABIA-on-2015-TRIA -Reauthorization-Proposed-Rule - May 31, 2016Concept Proposal to Improve Disclosure of Direct Purchases and Bank Loans Regulatory Notice - May 27, 2016Joint Comments to DOE on Methodologies for Reporting Student Fees - May 27, 2016ABA Comment Letter on Alignment of FR Y-15 and 2052a Implementation - May 12, 2016ABA Letter to OCC Re EGRPRA - May 12, 2016Joint Trades Letter Regarding CISA Implementation - May 11, 2016Comment to the Bureau on Qualitative Consumer Education Generic Clearance - May 9, 2016ABA SIFMA AMG Joint Comment Letter to FinCEN Re FBAR - May 9, 2016ABA Comment Letter on 18-Month Examination Cycle Eligibility - April 29, 2016ABA Comment Letter on FRB Interim Final Rule on Dividends on Stock - April 28, 2016Comment Letter to CFPB on Rural Definition - April 26, 2016ABA ABASA Joint Comment Letter to Treasury on the Evolution of the Market Structure - April 22, 2016CECL Letter to Banking Agencies on Cost vs. Benefits - April 20, 2016CECL Letter to FASB on Costs Benefits Model of Impairment - April 15, 2016SEC Transfer Agent Concept Release Letter - April 14, 2016Comment on Federal Finance Agency's Proposed Rulemaking on Acquired Member Assets Regulation - April 13, 2016ABA's Letter to FinCEN on Bank Secrecy Act Currency Transaction Report Proposal - April 4, 2016Comment on NACHA's Third-Party Sender Registration Comment Request - April 1, 2016Comments to NYDFS' Transaction Monitoring and Filtering Program Requirements Proposal - March 31, 2016ABA Response to EGRPRA Fourth Request for Comments - March 22, 2016ABA Letter to Basel Committee on Step-In Risk Proposal - March 17, 2016ABA Comment Letter to FHFA on Duty to Serve - March 17, 2016ABA and CBA File Comments to the Bureau's HMDA Resubmission Guidelines - March 14, 2016ABA Follow-Up Letter to OIRA Re Meeting on DOL Fiduciary - March 11, 2016ABA Letter to IRS Re Executor Basis Reporting - March 11, 2016ABA Final Letter to US Regulators on Basel Proposal - March 11, 2016FDIC Proposal on Small Bank Assessments - March 7, 2016Letter to FDIC's Comment Request on Small Business Lending Survey - March 7, 2016OCC BSA/AML Quality of Risk Summary Form - March 4, 2016Joint Comment Letter to FRB re Volcker Legacy Illiquid Funds - March 1, 2016ABA Comment Letter for Step-In Comment Extension Request - February 25, 2016OIRA Letter Requesting Meeting on DOL Fiduciary Re-Proposal - February 25, 2016Joint Comment Letter to OCC on HLTV Proposal - February 22, 2016Joint Trades Letter to Federal Reserve System on Proposed Total Loss-Absorbing Capacity (US Domestic G-SIBs) - February 19, 2016Joint Trades Letter to Federal Reserve System on Proposed Total Loss-Absorbing Capacity (Foreign G-SIBs) - February 19, 2016ABA Comment Letter to OCC Regarding Recovery Planning - February 16, 2016ABA Comment Letter to FASB on Fair Value Disclosure Requirements - February 12, 2016ABA Comment to FASB on the Exposure Draft Disclosures by Business Entities about Government Assistance (ED). - February 8, 2016ABA Letter to NCUA RE: Chartering and Field of Membership Manual - February 5, 2016Joint Trades Letter on LCR Disclosure Requirements - February 2, 2016Joint Letter on Proposed Changes to FR Y-9C - February 1, 2016ABA Letter to IRS Re Executor Basis Reporting - January 28, 2016Letter to FinCEN on the Regulatory Impact Assessment (RIA) and Initial Regulatory Flexibility Analysis (IRFA) for the proposed rulemaking on Customer Due Diligence - January 27, 2016Letter to Treasury Secretary Lew on Recent Flooding in the Midwest - January 21, 2016ABA ABASA Joint Comment Letter to CFTC regarding SD De Minimis Exception Preliminary Report - January 19, 2016Joint Trade Association Comment Letter on the Proposed National Survey of Existing Mortgage Borrowers - January 11, 2016Joint Letter to FinCEN Requesting Comment Deadline Extension on the Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis - January 8, 2016ABA, TCH and FSR Response to FDIC Proposal to Implement DFA §334 - January 5, 2016 Return to top 2015 Joint Trades Letter to FDIC on Brokered Deposits - December 28, 2015ABA Letter to BIS on Correspondent Banking - December 7, 2015ABA Letter to FDIC on Small Business Lending Survey - December 7, 2015Joint Comment Letter on Proposed FFIEC Changes to the Call Report - November 17, 2015ABA Comment Letter to the Bureau on Survey Regarding Overdraft Disclosure Forms - October 30, 2015ABA Comment to FinCEN on AML Reg Proposal for Investment Advisers - October 30, 2015Joint Trades Letter to Treasury Re myRA Request for Information - October 23, 2015ABA Comment Letter to FRB re FR Y-15 - October 19, 2015ABA Comment on NACHA Request for Comment on Third-Party Sender Registration - October 9, 2015ABA and TCH Comment on the Exposure Draft Contingent Put and Call Options in Debt Instruments (ED) - October 5, 2015ABA and TCH Comment on the Exposure Draft Effect of Derivative Contract Novations on Existing Hedge Accounting Relationships (ED) - October 5, 2015ABA Comments on Proposed Changes to the FHA's Loan-Level Certification Form, HUD 92900-A - October 1, 2015Associations Ask Bureau to Re-submit PRA Request for Approval of a Consumer Survey of Overdraft Disclosure Forms - September 30, 2015Comment Letter to Treasury Online Market Place - September 30, 2015ABA Comments on Audit Quality Indicators - September 29, 2015Comment Letter on Proposed Changes to Capital Plan Rule - September 24, 2015Department of Labor Proposed Rule on the Definition of Fiduciary (Conflict of Interest Rule) - September 22, 2015Joint Comment Letter to CFTC on Cross Border Margin Uncleared Swaps - September 14, 2015FDIC Proposal on "Small Bank Assessments" - September 11, 2015Joint Comment Letter on Interest Rate Risk - September 11, 2015ABA IRAG Information Reporting Letter to IRS - September 11, 2015ABA Comment Letter to SEC on Audit Committee Disclosures (CR) - September 8, 2015ABA Comments to FHA on Proposed Claims Filing Deadlines and Termination of Insurance - September 4, 2015Comments on Department of Labor's Overtime Proposal - September 4, 2015ABA Response to EGRPRA Third Request for Comments - September 3, 2015ABA Urges Bureau to Fix Flaws on the Consumer Complaint Database - August 31, 2015ABA Comment Letter to NCUA on Member Business Loan; Commercial Lending - August 28, 2015ABA Comment Letter to SEC on Possible Revisions to Audit Committee Disclosures - August 6, 2015ABA Comment Letter to FASB on Improvements to Employee Share-Based Payment Accounting - July 31, 2015ABA Comment Letter to PCAOB on The Auditor's Use of the Work of Specialists - July 28, 2015ABA-TCH-CBA on FDIC Large Bank Deposit Insurance Determination Modernization - July 27, 2015ABA Comment Letter to FHFA on Housing Prices Index - July 27, 2015ANPR Regarding Large Bank Deposit Insurance Determination Modernization - July 27, 2015Liquidity Coverage Ratio Comment Letter - July 24, 2015Department of Labor Proposal on the Definition of Fiduciary - July 21, 2015Joint Comments to the Bureau on Arbitration Study - July 13, 2015ABA Commends TRID Implementation Delay - July 7, 2015Joint Comment on Department of Education's Proposed Rule on Campus Bank Accounts - July 2, 2015ABA Comment Letter on Same Day ACH Service - June 24, 2015ABA Comment Letter to IRS Re Cost Basis Reporting on Bonds - June 24, 2015ABA Comments to CSBS on Non-Bank Mortgage Servicers Standards - June 22, 2015FR 2420 Report of Selected Money Market Rates Comment Letter - June 8, 2015Joint Supplemental Letter to Multiple Agencies on Reproposed Margin and Capital Requirements for Covered Swap Entities - June 1, 2015MSRB G-42 Fiduciary Duty SEC CL - May 29, 2015Associations Request for Comment Extension on Proposed Rule re: Campus Bank Accounts - May 29, 2015Joint Letter to CFPB on Arbitration - May 21, 2015Letter to Federal Reserve on LEI in FR Y-6, FR Y-7, and FR Y-10 Forms - May 19, 2015ABA FRB Reg D EBA Interest Comment Letter - May 18, 2015ABA Comments on CARD Act RFI - May 18, 2015HSA Council Cadillac Tax Comment Letter to IRS - May 15, 2015ABA Response to EGRPRA Second Request for Comments - May 14, 2015ABA Letter to CFPB on TRID Implementation re: ABA Survey on TILA/RESPA Integrated Disclosure Rule - May 13, 2015Associations Support FinCEN's Goal in Protecting U.S. from ML/TF, Ask for Clear Guidance - May 12, 2015Request to Determine Whether CFPB Tested the Scrubbing Standard on Complaint Database - May 5, 2015Bank Loan Disclosure NFMA Recommended Best Practices - May 4, 2015ABA Comment Letter to Basel re: Guidance on Accounting for Expected Credit Losses - April 30, 2015Letter to US Agencies re: Basel Committee's Guidance on Accounting for Expected Credit Losses - April 29, 2015ABA Letter Requesting Extension of Comment Period to DOL Fiduciary Re-Proposal - April 28, 2015Joint Trades Request Extension of Department of Labor Fiduciary - April 21, 2015ABA Comment on CFPB Final Policy Statement, Consumer Complaint Narratives - April 8, 2015Basel Proposal and Improvement to the U.S. Process for Adopting International Standards - April 6, 2015GSIB Surcharge Comment Letter - April 3, 2015Basel Standardized Proposal and Improvements to the U.S. Process for Adopting International Standards - April 3, 2015Joint Comments on Model Safe Accounts - March 30, 2015ABA Comments on Amendments Relating to Small Creditors and Rural or Underserved Areas Under the Truth in Lending Act - March 30, 2015Joint Trades Letter to House re: THUD for FY2016 - March 27, 2015Joint Trades Letter to Senate re: THUD for FY2016 - March 27, 2015ABA Comment Letter to FSOC on Asset Management Products - March 25, 2015ABA Requests Comment Extension on RFI Regarding Credit Card Market - March 24, 2015ABA Comments to CFPB re: Prepaid Accounts under Regulation E and Regulation Z - March 23, 2015ABA Comment Letter to NAIC on Cyber Security Policy - March 23, 2015Joint Letter to CFPB re: Regulatory Phase-In Period - March 18, 2015ABA Comments on Mortgage Servicing Proposal - March 16, 2015JOBS Act Implementation Regulations - February 27, 2015Joint Comment on NACHA Request for Comment on Same Day ACH - February 26, 2015IRS Notice on Form 5500 Changes - February 20, 2015Joint Comments to Cordray on Indirect Auto Lending 2015 - February 18, 2015ABA Comment Letter re: CSBS Draft Model Regulatory Framework - February 16, 2015ABA Welcomes Same-Day ACH Settlement Plan - February 4, 2015Joint Trades Letter to Financial Stability Board on Total Loss Absorbing Capacity for Global Systemically Important Banking Groups - February 2, 2015Joint Trade Comment Letter on FR 2052 - February 2, 2015ABA Files Additional Comment on Military Lending Act Proposal - January 16, 2015ABA Letter Proposed Changes to the Membership Requirements for FHLB System - January 13, 2015ABA Letter to FASB Re: Workshop for CECL Impairment Proposal - January 13, 2015ABIA Letter re: Proposed Changes to the Membership Requirements for FHLB System - January 12, 2015ABA Comment BCBS Corporate Governance Principles - January 9, 2015Joint Comment Letter on 408b2 Focus Group ICR - January 5, 2015 Return to top 2014 ABA Reply Comments to FCC Re: Petition for Exemption of the American Bankers Association Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991 - December 19, 2014Letter to FHFA re: Proposed Changes to the Membership Requirements for FHLB System - December 19, 2014ABA, ABIA Seek Lender Discretion on Insuring Detached Structures - December 18, 2014ABA Comments on Military Lending Act Proposal - December 18, 2014Associations Offer Recommendations to CFPB No-Action Letters Proposal - December 15, 2014Joint Comments on OFAC Ukraine-Related Sectoral Sanctions - December 11, 2014ABA Letter to HUD Requesting Guidance on SCRA Disclosure Form - December 3, 2014ABA Comment Letter to Multiple Agencies on Uncleared Swaps Margin - November 24, 2014Joint Letter on Reproposed Margin and Capital Requirements for Covered Swap Entities - November 24, 201411-19-14ABABrokerageWindowsinParticipant-DirectedIndividualAccountPlansCommentLetter - November 19, 2014Comment on DOL Brokerage Windows in Participant-Directed Retirement Plans - November 18, 2014Joint Letter to DoD Requesting Extension of Military Lending Act Proposal - November 18, 2014Joint Letter to DoD Requesting Joint Meeting re: Military Lending Act - November 18, 2014ABA Comment on Guaranteed Loanmaking and Servicing Regulations - November 17, 2014ABA Comment on TILA RESPA Disclosures - November 10, 2014ABA and CBA Joint Comment on the Proposed Amendments to Regulation C (HMDA) - November 10, 2014ABA Comments to PCAOB on the Staff Consultation Paper - Auditing Accounting Estimates and Fair Value Measurements - November 10, 2014Joint Letter re: CFPB Proposed Amendments to HMDA Reporting Data - November 7, 2014ABA Comment on CRA Q&As - November 7, 2014Joint Trades Letter re: CFPB Proposed Amendments to HMDA Reporting Data - October 29, 2014ABA on NACHA Request for Comment re: Compliance and Operational Topics - October 24, 2014ABA Comment to FCA Re: Proposed Rule to Amend Regulations Governing the Eligibility of Investments Held by Farm Credit Banks - October 23, 2014ABA Comments to FHFA on Single Security Structure - October 13, 2014Response to Basel Committee Consultative Document on Pillar 3 Disclosure Requirements - October 10, 2014ABA Letter to Federal Reserve Re: Tax Rate Calculations under the DFA Stress Process - October 10, 2014Joint Letter requesting MLA Extension Oct 2014 - October 8, 2014ABA and BAFT Say Customer Due Diligence Proposal Too Costly for Banks - October 3, 2014ABA Comments on NCUA Fixed Asset Ownership Proposal - September 26, 2014FDIC Proposal on (1) Measurement of Counterparty Exposures for the HCI Scorecard and (2) Custodial Bank Deduction from its Assessment Base - September 22, 2014ABA Supports FinCEN’s Imposition of Special Measure Against FBME, Offers Suggestions - September 22, 2014ABA Comment on CFPB's Consumer Complaint Database - September 22, 2014Extension Request re: Servicing Section of FHA Single-Family Housing Handbook - September 19, 2014ABA Comment Letter on Mobile Financial Services - September 10, 2014ABA Comments to FHFA on Guarantee Fees - September 8, 2014ABA Request to FHFA on Extension to File re: FHLB Membership Requirements - September 4, 2014ABA Response to EGRPRA First Request for Comments - September 2, 2014Comment Letter to OCC on Licensing - September 2, 2014Comment Letter to OCC on EGRPRA Review: Fiduciary Regulations - September 2, 2014Letter to MSRB on Proposed Rule G-44 - August 26, 2014Letter to MRSB on Proposed Revisions to Rule G-42 - August 25, 2014ABA Opposes CFPB's Debt Collection Survey - August 19, 2014ABA Letter to NACHA on ACH Network Risk and Enforcement Ballot #1-14 - August 15, 2014Joint Trades Letter to FRB on Capital Plan Rule - August 11, 2014ABA Comment Letter to FRB on Midsize Bank Concerns - August 11, 2014Comment on OCC Integration of Licensing Rules - August 8, 2014CBA-ABA Comment on Big Data Implications - August 5, 2014ABA Letter to FASB on June 2014 Workshops - July 22, 2014Extension Request on CFPB Consumer Complaint Database - July 21, 2014ABA Comment Letter to FASB on Exposure Draft: Conceptual Framework for Financial Reporting - Chapter 8: Notes to Financial Statement - July 14, 2014ABA Comment on CFPB Privacy Proposal - July 14, 2014Letter to the Basel Committee Relative to a Consultative Document on Pillar 3 Disclosures - July 11, 2014ABA Comments to CFPB on ATR-QM DTI Requirement & Small Creditor QM Exemption - July 7, 2014Joint Trades Supplemental LCR Comment Letter - July 1, 2014 Joint Comment on Phone Survey Exploring Consumer Awareness of Credit Card Agreements - June 30, 2014Comment Letter to NCUA on Associational Common Bond Requirements - June 20, 2014Proposed Revisions to Eligible Guarantee Definition - June 13, 2014Joint Comment Letter on the Proposed Rule to Modify the Denominator of the U.S. Supplementary Leverage Ratio and the Enhanced Supplementary Leverage Ratio - June 13, 2014Joint Comments on CFPB's Request for Information on Consumer Financial Behavior Study - June 12, 2014ABA Comments on Minimum Requirements for Appraisal Management Companies - June 9, 2014 Trade Associations Support Temporary Exception in Remittance Proposal - June 6, 2014ABA Requests Additional Time to Comply with Flood Insurance Coverage for Other Residential Buildings - June 5, 2014ABA Says Changing Weight or Dimensions of U.S. Coins too Costly for Banks - June 5, 2014ABA Comments to CFPB on Cure Provisions under the Ability to Repay Rule - June 5, 2014ABA Letter to IRS Re Unbundling of Trustee Fee Rule - May 30, 2014Joint Trades Comment Letter on LCR Daily Calculation Requirement - May 19, 2014ABA Says Further Discussions Needed in NACHA's Proposed Expansion of Addenda Records - May 16, 2014Trade Associations Ask CFPB to Extend Reg P Comment Deadline - May 13, 2014FHA Prepayments; Eliminating Post-Payment Interest Charges - May 12, 2014ABA Suggests Refinements to CFPB Debt Collection Study - May 6, 2014Joint Trade Comment to Fed on Reg CC, Availability of Funds and Collection of Checks - May 2, 2014Letter to MSRB on Draft Rule G-44 Supervisory and Compliance Obligations of Municipal Advisors - May 1, 2014Joint Trades Letter to FRB re: Physical Commodities ANPR - April 16, 2014Joint Trades Comment Letter on FRB re Merchant Banking Activities - April 16, 2014Comment Letter re: Implementation Plans for the Homeowner Flood Insurance Affordability Act - April 15, 2014Joint Trades Letter to OMB re Section408(b)(2) Guidance Requirement - April 11, 2014ABA, CBA: Student Aid Rulemaking Casts Too Wide a Net - April 2, 2014Letter to CFPB on Defining Larger Participants of the International Money Transfer Market - April 1, 2014Joint Trades Comment Letter to OCC on Integration of 12 CFR Parts 30 and 170 - March 28, 2014Joint Trades Comment Letter to BCBS on Leverage Ratios - March 17, 2014ABA Comment Letter on OFR Asset Management and Financial Stability Report - March 14, 2014ABASA Letter to CFTC Regarding Cross-Border Swaps Guidance - March 10, 2014ABA Comment Letter to MSRB on Fiduciary Duty - March 4, 2014ABA Comment Letter on Volcker Rule Interim Final Rule on TruPS CDOs - March 3, 2014Joint Comment Letter to CFPB's ANPR on Debt Collection - February 28, 2014ABA Comment Letter on Interagency Addendum to Tax Allocation Policy Statement - February 26, 2014Joint Trades Comment Letter on FDIC Single Point of Entry Release - February 18, 2014Federal Reserve Policy on Payment System Risk - February 10, 2014ABA Comment on Regulation J - February 10, 2014ABA, Groups Urge Delay on 'Know Before You Owe' - February 7, 2014Joint Comment Letter on the Proposed Interagency Policy Statement Establishing Joint Standards For Assessing the Diversity Policies and Practices of Regulated Entities - February 7, 2014Joint Comment on Complementary Activities, Merchant Banking Activities and Other Activities - February 7, 2014 Joint Comments to OMWI on the Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Regulated Entities - February 6, 2014Letter to FDIC, FRB, OCC on the Impact of Final Basel III Capital Rule on Subchapter S Banks - February 3, 2014ABA Liquidity Coverage Ratio Comment Letter - January 31, 2014ABA Corporate Trust Liquidity Coverage Ratio Coverage Comment Letter - January 31, 2014Joint Trades Comment Letter on Liquidity Coverage Ratio - January 31, 2014ABA Comment Letter on FASB Adoption of Final Impairment Model - January 24, 2014ABA Comment Letter on IASB Conceptual Framework Paper - January 21, 2014Comment on Improving ACH Network Quality by Reducing Exceptions - January 13, 2014Comment on Improving ACH Network Risk and Enforcement Topics - January 13, 2014 ABA Requests for Extension of Effective Date, Municipal Advisor Final Rule - January 10, 2014 Return to top 2013 Joint Comment to CFPB and HUD Requesting Technical Assistance on Homeownership Counseling Disclosures - December 22, 2013Comment Letter to NCUA on Capital Planning and Stress Testing - December 17, 2013ABA Comment on Fed's Payment System Consultation Paper - December 13, 2013ABA Comment Letter to PCAOB Proposed Auditing Standards on Auditor Reports - December 11, 2013Joint Comment on Interagency Proposal to amend Flood Insurance Rules - December 6, 2013ABA Comment Letter to Postal Regulatory Commission on Proposed Exigent Rate Increase - November 26, 2013Joint Comments to CFPB's October 23 2013 Interim Final Rule - November 22, 2013 - November 22, 2013Complex Liquidity Report Comment Letter - November 18, 2013ABA Comment Letter to FDIC Re Basel III - November 12, 2013Comment on the Consultative Paper on AML/CFT Risk Management - October 31, 2013Credit Risk Retention Proposed Rule: Joint Coalition Letter and White Paper from The Coalition for Sensible Housing Policy re: QRM, - October 30, 2013Joint Trade Association on Credit Risk Retention Re-Proposed Rule - October 30, 2013ABA Comments to Credit Risk Retention Proposed Rule - October 30, 2013ABA Comments to HUD on QM Definitions for FHA Programs - October 30, 2013ABA Comments on HUDs FHA Qualified Mortgage Definition - October 30, 2013ABA Letter to IRS S Corp NIIT Guidance - October 29, 2013Joint Trade Association Comment Letter on Proposed Revisions to the Banking Organization Systemic Risk Report (FRY 15) - October 29, 2013Petition for Exemptive Relief and Interim No-Action Relief for Bank Holding Companies of Banks Eligible for the End-User Exception from Mandatory Clearing - October 25, 2013ABA Letter to the FDIC, FRB and OCC requesting the definition of “Eligible Guarantor” be removed from the Basel III Rule. - October 24, 2013Comment Letter to NCUA regarding Charitable Donation Account - October 21, 2013Joint Trades Comment Letter to OCC, FRB and FDIC Re: Regulatory Capital and Enhanced Supplementary Leverage Ratio Standards - October 21, 2013Proposed Changes for Basel III Capital in Call Report Schedule RC-R & Form FR Y-9 & FFIEC Form 101, - October 11, 2013TCH-ABA Comment Letter-Notice 2013-35 on Conclusive Presumption Regulations - October 8, 2013FHFA Joint Letter GSE 2014 Multifamily Scorecard - October 8, 2013ABA Comment To CFPB on Overdraft Program Research - October 7, 2013ABA Comment Letter on Insurance Contracts (ED) - October 1, 2013ABA Letter to Basel Committee on Banking Supervision Re Credit Risk Exposures - September 27, 2013ABA Letter to CFPB on Company Portal Services Agreement - September 25, 2013ABA Letter to the Agencies Re: Proposed Supervisory Guidance on Implementing Dodd-Frank Act Company-Run Stress Tests for Banking Organizations with Total Consolidated Assets of More than $10 Billion but Less than $50 Billion - September 25, 2013ABA Comment to NACHA Re Clarification and Use of R03 and R04 - September 20, 2013ABA/GFMA Joint Trades Comment Letter Re: Basel III Leverage Ratio Framework and Disclosure Requirements - September 20, 2013ABA Letter on Cost Basis Rules for Debt Instruments - September 18, 2013ABA Letter to SEC Re Money Market Mutual Fund Proposal - September 17, 2013CFTC Cross-border Guidance and Overseas Branches to the Prudential Regulators - September 6, 2013ABA Letter Re CFTC Cross-border Guidance and Overseas Branches to the Treasury Department - September 6, 2013ABA Comment Letter on Leases - August 28, 2013Joint Trade Report of Selected Money Market Rates (FR 2420) - August 27, 2013FRY-14 Data Collection Comment Letter - August 26, 2013Comment on Generic Clearance for Consumer Complaint and Information Collection System - August 23, 2013ABA/SIFMA Comment Letter Re IRS Draft Forms for IRAs - August 20, 2013ABA Comment Letter on FTC's Proposed Amendment to Telemarketing Sales Rule - August 8, 2013ABA Comment Letter to DOL re ANPR on Lifetime Income Illustrations - August 7, 2013Joint Comment Letter on Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute Resolution Provisions in Credit Card Agreements - August 6, 2013Joint Comment Letter on Consumer Credit Protections for Servicemembers, - August 1, 2013ABA Comment to CFPB on Mortgage Servicing - July 22, 2013ABA Mortgage Origination Comment Letter - July 22, 2013Joint Comment to CFPB on Commercial Lending Dodd-Frank Appraisals Section 1474 Concerns - July 19, 2013ABA Letter to IRS re Industry Issue Resolution Program Application - July 6, 2013ABA-ABASA Letter Re SEC RFI on Duties of Brokers, Dealers and Investment Advisers - July 5, 2013ABA Letter to IRS re Timing of CP-2100 Notices for 2012 IRS Form 1099-K, Payment Card and Third Party Network Transactions - July 3, 2013ABA Comment Letter on the BCBS Consultative Document, External Audits of Banks - July 2, 2013ABA Comment Letter on Exposure Draft ED/2013/3: Financial Instruments - Expected Losses - July 1, 2013ABA Comment Letter to NACHA on Clarification of Third Parties in the ACH Network - June 28, 2013Joint Comment to FinCEN on Lebanese Exchange Houses as Primary Money Laundering Concern - June 24, 2013Joint Comment Letter Requesting Extension re DOL's Lifetime Income ANPRM - June 18, 2013ABA Comment Letter to FASB on the Exposure Draft Accounting for Investments in Qualified Affordable Housing Projects (ED), - June 17, 2013ABA Comment Letter to FRB re Supervision and Regulation Assessments for BHCs and SLHCs with $50+ Billion and NBFCs Supervised by the Fed - June 14, 2013ABA Comment Letter on Clearing Deadline for Category 2 Entities - June 8, 2013Joint Trades Comment Letter Requesting Extension of CFTC Cross-Border Guidance - June 6, 2013ABA Comment Letter on Proposed Amendments to the CFPB's Mortgage Servicing Rules - June 3, 2013ABA Comment Letter to CFPB on Amendments to Mortgage Rules Under RESPA-TILA - June 3, 2013ABA Comment on OCC/FDIC Guidance on Deposit Advance Products - May 30, 2013ABA/ABIA Letter to FHFA on Lender Placed Insurance Proposal - May 24, 2013ABA/ABIA Letter to CFPB on Credit Insurance Premium Delay - May 23, 2013ABA Comment Letter on Proposed Changes to Community Reinvestment Act - May 17, 2013ABA Comment Letter to FASB on the Exposure Draft: Recognition and Measurement of Financial Assets and Financial Liabilities - May 15, 2013ABA Comment Letter to FASB on the Exposure Draft: Financial Instruments - Credit Losses - May 14, 2013ABA Comment Letter to IASB and FASB on the Financial Instruments Credit Loss Exposure Draft - May 14, 2013Comment Letter to Joint Agencies re Reporting Templates - May 14, 2013ABA Comment Letter to CFPB on Proposed Amendments to 2013 Escrows Final Rule Reg. Z - May 3, 2013ABA Joint Comment Letter to Fed re 165 FBO Proposal - April 30, 2013Joint Comment Letter to FDIC, FRB and OCC re Call Report - April 22, 2013Joint Comment Letter with The Clearing House, CBA, The Financial Services Roundtable, and ICBA on Call Report - April 22, 2013ABA/ABASA Comment letter to FDIC on Insured Deposits NPR - April 19, 2013Interagency Guidance on Leveraged Lending - April 11, 2013ABA Letter to OCC on Notice and Request for Comment re: BSA/Money Laundering Risk Assessment - April 8, 2013Comment Letter to NACHA on Compliance and Operational Topics - April 5, 2013Joint Comment Letter on Proposed Revisions to FFIEC 009 and FFIEC 009a - April 1, 2013ABA Letter to the IRS Re Type III Support Organizations - March 29, 2013ABA Comment on FEMA's decision to rescind the Mandatory Purchase of Flood Insurance Guidelines - March 28, 2013ABA Comments to FFIEC Guidance on the Use of Social Media - March 26, 2013ABA Comment on CFPB's Request for Comment on Campus Financial Products - March 18, 2013Joint Association Comment Letter to the FRB Board - March 15, 2013ABA Comments on Points and Fees under the Ability to Repay Rule - February 25, 2013ABA Comments on QM and Ability to Repay Standards - February 25, 2013ABA/TCH Comment Letter on Proposed Regs: IRS Truncated Tax ID Numbers on Payee Statement - February 21, 2013ABA Comment on Request for Information on Credit CARD Act's Impact - February 19, 2013Joint Comment Letter to FRB Regarding Data Collection - February 19, 2013ABA Comment Letter to FRB Regarding Scenario Development Policy - February 15, 2013 Joint Comment on CFPB Proposal on Trial Disclosures - February 15, 2013ABA Comment Letter to IRS Regarding 1099 Notice 2012-65 - February 11, 2013Letter to NCUA on Thrivent Field of Membership - February 4, 2013ABASA Comment Letter to FSA Regarding 'CP12-23 Depositor Preference' - January 30, 2013 Joint Comment on Proposed Revisions to Remittance Rules - January 30, 2013ABA Comment on Proposal to Amend the Definitions of Transmittal of Funds and Funds Transfer - January 24, 2013FSOC MMF Reform Comment Letter - January 18, 2013ABA Supports Proposed Delay of Effective Date of Remittance Rules - January 15, 2013Comment Letter on Proposed Rule: “ability to pay” on credit card account - January 7, 2013 Return to top 2012 ABA Comments on Exposure Draft Clarifying the Scope of Disclosures about Offsetting Assets and Liabilities - December 18, 2012ABA Letter to Agencies on Finalizing Volcker Rule Proposal - December 17, 2012ABA Comments to FHFA on State-Level Guarantee Fee Pricing for Fannie Mae-Freddie Mac - November 26, 2012Letter to NCUA on Chartering and Field of Membership Manual for Federal Credit Unions - November 19, 2012Joint ABA/CBA Comment Letter on Generic Clearance for Collection of Info on Compliance Costs - November 9, 2012ABA Comments on COSO Proposal on Internal Control Framework - November 8, 2012ABA Comments to CFPB Regarding Proposed Rule Amending RESPA-TILA Disclosures - November 6, 2012ABA Mutual Banks Comment Letter on Basel III - October 25, 2012ABA, SIFMA, and FSR Comment Letter on Basel III - October 22, 2012Comment Letter to CFPB on Prepaid Preemption - October 22, 2012MBSD Supplement to Joint Trades Letter on Basel III - October 22, 2012FSR and ABA S&L Holding Company Letter in Basel III - October 22, 2012ABA Supplement to Joint Trades Basel III Letter - October 22, 2012Joint Comment Letter to Federal Reserve Regarding the Banking Organization Systemic Risk Report (FR-Y15) - October 19, 2012Pentagon Federal Credit Agreement Simplification Survey - October 17, 2012ABA Comment on Remittance Transfer Rules - October 17, 2012Comment on Proposal re: Loan Originator Compensation and “No-Point, No-Fee Mortgage Option - October 16, 2012ABA Comments to CFPB on ECOA Amendments Concerning Appraisals - October 15, 2012ABA Comments on Appraisals for Higher Risk Mortgage Loans - October 15, 2012ABA Comment Letter to CFPB on Proposed Mortgage Servicing Rules (Reg X and Reg Z) - October 9, 2012ABIA Comment Letter to CFPB’s RESPA (Regulation X) Mortgage Servicing Proposal - October 9, 2012ABA Comment Letter to NACHA on P2P Payments - October 1, 2012ABA Comment Letter on ABA FATCA Credit Card - September 26, 2012ABA Comment Letter to NACHA on IAT Modifications - September 24, 2012 Comment on NACHA IAT Modifications - September 24, 2012ABA Comment Letter to NACHA on Compliance and Operational Topics - September 24, 2012ABA Comment Letter to FASB on Disclosures about Liquidity Risk and Interest Rate Risk - September 21, 2012ABA Comment to Treasury on Foreign Exchange Forwards and Foreign Exchange Swaps - September 19, 2012Joint Request to FFIEC for ASC Extension - September 14, 2012Joint Letter on FHFA's proposed rule re: Property Assisted Clean Energy (PACE) programs - September 13, 2012 ABA Urges CFPB to Drop APR Proposal - September 10, 2012ABA Letter to IRS Re: Conclusive Presumption of Worthlessness - September 9, 2012ABA Comments on CFPB HOEPA Proposals - September 7, 2012ABA’s Coments on CFPB HOEPA Proposals - September 7, 2012ABA, TCH, and FSR Joint Comment Letter on CCAR - September 4, 2012Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act - August 27, 2012ABA Comment Letter 'Eligible Contract Participant (ECP) Definition' - August 24, 2012Letter to U.S. Reps to G20 on Convergence Pressures - August 23, 2012ABASA MSRB Financial Incentives Disclosure Letter - August 23, 2012ABA Comments to CFPB on Elderly Financial Abuse Prevention - August 20, 2012Joint Comments on MSRB Financial Incentives Disclosures - August 16, 2012Clearing Exemption for Certain Swaps Entered Into by Cooperatives, - August 16, 2012Joint Comment to CFPB on Generic Clearance for Collection of Information on Compliance Costs - August 13, 2012ABA Letter to NCUA on Maintaining Access to Emergency Liquidity - August 7, 2012Joint Comment Letter to OCC on Lending Limits - August 6, 2012TCH, ABA, and FSR Comment Letter on OCC Lending Limits - August 6, 2012ABA, The Clearing House Raise Concerns on FinCEN’s Proposed Special Measures Against CredexBank - July 30, 2012Comment Letter on Nonbank Supervision Risks - July 24, 2012ABA Comment Letter on Electronic Funds Transfers - July 23, 2012Comment on Notice of Proposed Policy Statement re: Disclosure of Consumer Complaint Data - July 19, 2012ABA Comment Letter on Indemnification Asset - July 16, 2012ABA Letter to IRS Commissioner on Conclusive Presumption of Worthlessness - July 13, 2012ABA Comments on CFPB Reopening of Proposed Amendments to Reg Z - July 9, 2012Joint Letter Requesting Extension on Basel III Comments - June 22, 2012Comment Letter on NACHA Security Framework - June 22, 2012Comment Letter to CFPB on Arbitration - June 22, 2012ABA Comment - ACH Security Framework - June 22, 2012ABA Letter to IRS Re FATCA and Foreign Trusts - June 18, 2012Comment Letter on FSA Farm Loan Program Proposal - June 12, 2012ABA Comments on FinCEN’s Request for Information re: Customer Due Diligence - June 11, 2012ABA Comment Letter to FinCEN on Customer Due Diligence - June 11, 2012Comment Letter on OCC STIFF Proposal - June 8, 2012ABA Streamlining Comment June 2012 - June 4, 2012CFTC Letter Second Amendment to Effective Date - May 30, 2012Joint Comment Letter to FDIC: Revised Definitions of Higher-Risk Consumer and C&I Loans and Securities in FDIC Large Bank Pricing - May 29, 2012ABASA Comment on Enhanced Prudential Standards - April 30, 2012ABA Recommends Changes to FATCA Proposal - April 30, 2012ABA Letter to OCC and FDIC Re: Annual Stress Testing - April 30, 2012ABA Comment Letter to FDIC & OCC re Section 165 Stress Testing Requirements - April 30, 2012ABA Comment Letter to FRB regarding Enhanced Prudential Standards - April 30, 2012Joint Trade Letter on Stress Testing to the FDIC & OCC - April 30, 2012Comment Letter Dodd-Frank Section 165/166 - April 27, 2012Joint Comment Letter to OCC & FDIC Re: Stress Testing Requirements under Dodd-Frank - April 27, 2012Comment to the Fed on Capital Plans; Proposed Agency Information Collection Activities - April 23, 2012Comment Letter on Internal Revenue Service Notice 2012-6 - April 20, 2012ABA Comments on CFPB Payday Lending Hearing - April 17, 2012ABA Impairment Letter to FASB re March 2012 Joint Meeting - April 16, 2012ABA Supports CFPB's Proposal on Privileged Bank Information - April 16, 2012 Joint Comments on "Know Before You Owe" Mortgage Loan Initiative - April 16, 2012Joint Comments on Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Covered Funds (Volcker Rule) - April 16, 2012 ABA Requests for Comment Extension on CFPB Inquiry on Overdraft Practices - April 10, 2012ABA Comment on CFPB Remittance Rule - April 9, 2012Joint Comment on CFPB Remittance Rule - April 9, 2012ABA Comments on Proposal to Update Internal Control Framework - March 16, 2012Supplemental Comment Letter on Volcker Rule - March 9, 2012ABA Comment Letter on Proposed Prototype Credit Card Contract - March 7, 2012Streamlining Comment Letter March 2012 - March 5, 2012Comment on Assessment of Fees on Large Bank Holding Companies and Nonbank Financial Companies Supervised by the Federal Reserve Board - March 5, 2012Joint Comment Letter from ABA, SIFMA, FSR, IIB, and The Clearing House - March 2, 2012Treatment of Unrealized Gains and Losses Under the Basel III Capital Framework - March 1, 2012ABA Comment Letter to IRS re Cost Basis - February 23, 2012Comment to NCUA on Rule Extending Regulatory Relief to all Federal Credit Unions - February 21, 2012Comment on Investments in Corporate Debt by Savings Associations - February 21, 2012ABA Comment Letter on Investment Companies - February 15, 2012Comment on Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant" - February 14, 2012 ABA Comment Letter re: Volcker Rule Proposal - February 13, 2012 Joint Trades Volcker Comment Letter - Hedge Funds - February 13, 2012Joint Trades Volcker Comment Letter - Proprietary Trading - February 13, 2012 ABA Letter re: Section 619 of DFA, Proprietary Trading - Hedge Funds and Private Equity - February 13, 2012ABASA Letter re: Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds - February 13, 2012 ABASA Letter re: Sec 619 of DFA, Proprietary Trading - Hedge Funds and Private Equity Funds - February 13, 2012 Extension Request: Notice of Streamlining Project - February 10, 2012ABA Comment Letter on Principal versus Agent Analysis - February 10, 2012ABA Comments on FHLBs Community Support Amendments - February 8, 2012ABA Comment on NPR re: Risk-Based Capital Guidelines - February 3, 2012ABA Comment Letter on Disclosure of Credit Card Data - January 30, 2012ABA Comment on Imposition of Special Measure Against Iran - January 27, 2012Comment to NCUA on Maintaining Access to Emergency Liquidity - January 25, 2012ABA Comment on Consolidated Reports of Condition and Income (Call Report) - January 20, 2012ABA Comment on Proposed Revisions to the FR Y-9C - January 20, 2012Comments regarding Proposed Rulemaking on the "Discriminatory Effects Standard" of the Fair Housing Act - January 17, 2012Comments Concerning Proposed Rulemaking On The "Discriminatory Effects Standard" of the Fair Housing Act - January 17, 2012ABA Comment Letter on FAF Proposal on Private Company Accounting - January 13, 2012 Return to top 2011 ABA Comment on CFPB Request for Generic Information Collection - December 30, 2011Comment on OCC Proposal to Remove Ratings from Non-Capital Rules - December 29, 2011ABA Comment on Standard Flood Hazard Determination Form - December 21, 2011ABA Comment on the Federal Housing Agency's (FHFA) Alternative Mortgage Servicing Compensation Discussion Paper - December 20, 2011ABA Comment on Regulation J Regarding Collection of Checks - December 19, 2011ABA Comment on Regulation D to Simplify the Administration of Reserve Requirements - December 19, 2011Letter to FSOC on Nonbank Financial Companies - December 19, 2011ABA Comments on FinCEN CMIR Proposal, Definition of Monetary Instrument - December 16, 2011Letter to NACHA re: Expedited Processing and Settlement - December 12, 2011 Risk-Based Capital Guidelines; Alternatives to Credit Ratings - December 9, 2011ABA Comment Letter on the Concept Release on Auditor Independence and Audit Firm Rotation (Concept Release) - December 9, 2011ABA Comments to CFPB on RESPA-TILA Integration - December 9, 2011ABA Letter to IRS Re Section 67(e) Proposal - December 6, 2011ABA Comment: Guidance and Proposed Revisions on Flood Insurance Q&As - December 1, 2011Joint Comment on Extension on Volcker Rule Proposed Regulations - November 30, 2011ABA Comment Letter to FASB and IASB on 3 Bucket Impairment Model - November 23, 2011 ABA Urges Principled Approach for Outreach to the Unbanked - November 18, 2011ABA Comment on FinCEN's Proposal: Mandatory E-filing by June 2012 - November 15, 2011Re-Proposal of Shelf Eligibility Conditions for Asset-Backed Securities - November 10, 2011Comment to IRS on Guidance of Portability of Deceased Spousal Unused Exclusion Amount - November 7, 2011Comment to FRB on Capital Plans: Proposed Agency Information Collection Activities - November 7, 2011Comment to FSB on the Consultative Document Understanding Financial Linkages - November 7, 2011Comment on Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant" - November 3, 2011Joint Comment on Proposed New Information Collection for Savings and Loan Holding Companies (SLHCs) - November 1, 2011Letter to the Agencies on a Supervisory Presumption that Every Exposure to an Investment Fund Warrants Securitization Treatment Unless Proven Otherwise - October 18, 2011ABA Letter to Fed on G20 High-Level Principles on Financial Consumer Protection - October 10, 2011ABA Comment to FCC Re: Petitions for Declaratory Ruling Concerning the Telephone Consumer Protection Act Rules - October 10, 2011ABA Comment Letter to IRS on Credit Union Common Bond Requirement - October 10, 2011Comment to NCUA: Proposed Amendments to Corporate Credit Unions - October 5, 2011Additional Comments on End-User Exception to Mandatory Clearing of Swaps and Security-Based Swaps - September 30, 2011Joint Comment on Debit Card Fraud Prevention Adjustment - September 30, 2011ABA Comment Letter to PCAOB Concept Release on Auditor Reports - September 30, 2011Joint Comment to CFPB on Interim Final Rules on Investigations, and Interim Final Rules of Practice Governing Adjudication Proceedings - September 26, 2011Joint Comment re: Consolidated Reports of Condition and Income - September 26, 2011 Joint Comment to CFPB on Disclosure of Records and Information - September 26, 2011Letter to CFPB on Alternative Mortgage Transaction Parity (Reg D), - September 22, 2011ABA Comment Letter to IRS Asks for Penalty Waiver on Merchant Reporting Rules - September 20, 2011Letter regarding disposition of REO properties held by Fannie, Freddie and FHA - September 15, 2011ABA Letter to OECD re: High-level Principles on Financial Consumer Protection - August 31, 2011Comment on Consultative Document: Globally systemically important banks: Assessment methodology and the additional loss absorbency requirement - August 26, 2011ABA to the Agencies: Don't Add New Overdraft Program Requirements - August 25, 2011ABA Comments on NACHA Pain Points Rules--Phase Two - August 19, 2011Comment on Credit Union Service Organizations (CUSO) - August 16, 2011Comment on Defining Larger Participants in Consumer Financial Products & Services Markets - August 15, 2011Capital Requirements of Swap Dealers and Major Swap Participants - August 12, 2011ABA Comments Suggest Regulatory Relief Actions to the CFPB - August 12, 2011ABA Comments on Amended Draft Mortgage Forms - TILA and RESPA Disclosures - August 10, 2011Inter-agency Proposal on Capital Planning for the Largest Banking Firms - August 5, 2011Joint Comment on Capital Plans, Regulation Y - August 5, 2011ABA Urges OCC to Withdraw Proposed Consumer Credit Product Guidance - August 4, 2011 ABA Urges OMB to Withhold General Approval of CFPB Consumer Response Intake Fields - August 1, 2011ABA Comment Letter on Proposal to Establish Credit Risk Retention Requirements - August 1, 2011ABA Comment Letter to SEC on Adoption of International Financial Reporting Standards - August 1, 2011ABA Comment on Stress Testing July 2011 - July 29, 2011ABA Addresses Concerns with Fed's Proposal on Remittances - July 22, 2011 Comment on Proposed Rule Amending Reg Z: Ability-To-Repay Requirements - July 22, 2011ABA Comment Letter on Proposed Rule Amending Regulation Z: Ability-To-Repay Requirements - July 22, 2011 Associations Offer Suggestions on Stress Testing Proposed Guidance - July 19, 2011ABA/ABASA Comment Letter on Margin and Capital Requirements for Swaps - July 11, 2011Comments to IRS on Credit Unions Associated Common Bonds - July 8, 2011ABA Comment to IRS on Credit Unions (associated common bonds) - July 8, 2011Comment on Proposed Order regarding Effective Date for Swap Regulation - July 1, 2011Comment re: OTS Integration, ABA Backs OCC on Pre-emption Standard - June 27, 2011ABA Seeks Comment Extension on Overdraft Guidance - June 27, 2011ABA Comment Letter to NACHA on Risk Management Enhancements - June 24, 2011Joint Comment on Retail Foreign Exchange Transactions - June 20, 2011Joint Letter requesting extension of Comment Period for Capital and Margin Requirements for Covered Swap Entities - June 17, 2011ABA letter requesting clarifications about FinCEN's FBAR Final Rule - June 10, 2011ABA Comment on NACHA Corporate Account Takeover - June 10, 2011Comment on Proposed Rule Implementing the Resolution Plan ("living wills") section 165(d) of Title I of DFA - June 10, 2011 Joint Trades Letter requesting Relief Under Section 774 of the DFA - June 10, 2011Comment re: Intent to Apply Supervisory Guidance S & L Holding Companies - June 6, 2011 Comment on Reg CC, Proposed Rule to Encourage Electronic Check Clearance and Return - June 3, 2011Joint ABA/BAFT-IFSA Comment on FinCEN's CISADA Proposed Rule - June 1, 2011 Comment on Incentive-Based Compensation Arrangements - May 31, 2011Comment on Assessment Rate Adjustment Guidelines for Large and Highly Complex Institutions - May 31, 2011Members of House Sent Letter Urging Regulators to Modify Risk Retention Proposal - May 31, 2011ABA Comment Letter on Merged Mortgage Disclosures - May 27, 2011ABA Comment Letter on Draft Mortgage Disclosure Forms - May 27, 2011ABA Comment Letter to IRS Requesting to Extend Truncation Program to All TIN Types - May 25, 2011Comment on Garnishment of Accounts Containing Federal Benefit Payments - May 24, 2011Comment Letter to Treasury re: Garnishment of Accounts - May 24, 2011Comment to SEC re: Missing Securityholders, Rule 17Ad-17, Transfer Agents', Brokers', and Dealers' Obligation to Search for Lost Securityholders - May 23, 2011ABA Comment on NPR Regarding the Risk Management Standards of Certain Financial Market Utilities - May 19, 2011ABA Comment Letter on Large Bank Reporting: Subprime and Leverage Loans - May 16, 2011Joint Letter to FRB re: Proposed Rulemaking implementing the repeal of the prohibition against payment of interest on Demand Deposits (Regulation Q) - May 16, 2011Joint Letter to FDIC re: Proposed Rulemaking on interest on deposits and deposit insurance coverage (Regulation Q) - May 16, 2011ABA Comment on Proposed Regulatory Reporting Revisions to the Call Report, TFR, and FFIEC Forms 002 and 002S - May 16, 2011Joint Letter Requesting Extension of Risk Retention Comment Period - May 13, 2011 ABA and the Clearing House Comment on CFPB's PRA Notice: Consumer Response Intake Fields - May 9, 2011 Comment on Core and Brokered Deposit Study Mandated by the Dodd-Frank Act - May 2, 2011ABA's Comment Letter on the Board's Proposal Regarding Mandatory Escrow and Disclosures on Higher-Priced Mortgage Loans (HPMLs) - May 2, 2011Comment to NCUA on Net Worth and Equity Ratio Proposed Rule - April 29, 2011ABA Letter on the IASB Exposure Draft: Offsetting Financial Assets and Financial Liabilities/FASB Exposure Draft: Offsetting - April 28, 2011ABA Comment Letter to FASB on Selected Issues about Hedge Accounting - April 26, 2011ABA Comment on Federal Government Participation in the Automated Clearinghouse - April 25, 2011 ABA Comment Letter to FRB on Equal Credit Opportunity Act - April 13, 2011 Comment re: Proposed Rules on Risk-Based Pricing Notices (Regulation V) - April 13, 2011ABA Comment: Public Hearing on Definition of Fiduciary - April 12, 2011Letter to FDIC on Amendments to Deposit Insurance Regulations - April 12, 2011ABA Comment Letter on Summary of Deposits for OTS Institutions - April 11, 2011ABA/The Clearing House Letter on Basel II Pillar 3 Concerns - April 11, 2011ABA/CH/IIF/ISDA/SIFMA Letter on the Agencies Market Risk Capital Proposal - April 11, 2011Proposal to Require Call Report Adoption - April 11, 2011Exemption From Tax on Corporations, Certain Trusts, Etc. (Revenue Ruling 2011-1) - April 11, 2011ABA Comment on Draft MSRB Rule G-36 (On Fiduciary Duty of Muni Advisors) - April 11, 2011 ABA Comment on Cost of Funds Indices (Notice of Intent to Discontinue) - April 11, 2011 ABA Comment on Proposal to Standardize Holding Company Reporting - April 11, 2011ABA Comment Letter to NACHA on IAT Modifications and Refinements - April 8, 2011ABA Comment Letter to DOL on Reducing Regulatory Burden - April 8, 2011ABA Comment Letter on Proposed Change in the Rules Relating to the Taxation of Foreign Corporations - PRN 2011-038-Proposed Amendment: N.J.A.C. 18:7-1.8 - April 8, 2011ABA Comment Letter on IRS Proposed Regulations on Reporting Interest to Nonresident Alien Individuals - April 7, 2011ABA Comment Letter to IASB and FASB on Impairment - April 1, 2011 ABA Comment Letter on Truth in Lending (TILA) Regulation Governing Compensation to Mortgage Loan Originators - March 29, 2011ABA Offers Suggestions to FinCEN re: CTR and DOEP Proposed Data Fields - March 28, 2011ABA Comment on FDIC Interim Rule Implementing the Orderly Liquidation Authority Provision of the Dodd-Frank Act - March 28, 2011ABA Comment on NACHA's ACH Security Framework - March 25, 2011ABA Comment on Membership Requirements for Members of FHLBs - March 17, 2011ABA Comment to OCC on Loans in Areas Having Special Flood Hazards - March 15, 2011HUD Determines that Existing RESPA Rules Apply to "Table Funding" and "Secondary Market Transactions" - March 11, 2011Comments regarding FSOC's Study & Recommendations Regarding Concentration Limits on Large Financial Companies, - March 10, 2011ABA Comment Letter to IRS on Credit Unions - March 10, 2011ABA Letter to Congress on NRA Regulations - March 10, 2011ABA Letter to Congress on NRA Regulations - March 10, 2011ABA Comment to IASB on Exposure Draft: Hedge Accounting - March 9, 2011ABA Comment on Risk-Based Capital Floor Proposal - February 28, 2011Joint Comment on Revised Interim Final Regulation Implementing Provisions in the Mortgage Disclosure Improvement Act - February 28, 2011 ABA Comment on MSRB Pay to Play Rule for Municipal Advisors - February 25, 2011Comment on NPRM To Require Supervision and Regulation of Certain Nonbank Financial Companies - February 24, 2011 ABA Addresses Burden CFPB Will Impose on the Banking Industry - February 24, 2011ABA Comment on Debit Card Interchange Fees - February 22, 2011Joint Comment on Debit Card Interchange Fees - February 22, 2011ABA Comment on NCUA Proposed Rule on Accuracy of Advertising - February 22, 2011ABA Comment on SEC Registration of Municipal Advisors - February 22, 2011Joint Comment Letter to CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties - February 22, 2011Comment to SEC/CFTC on End-User Exception to Mandatory Clearing of Swaps - February 22, 2011ABA Comment on FTC Preliminary Staff Report re: "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers" - February 17, 2011ABA Letter to the Federal Reserve and other Agencies Regarding the Potential Treatment of Exposures to Investment Companies as Securitization Exposures - February 15, 2011Comment to NCUA on Sample Income Data to Meet the Low-Income Definition - February 14, 2011ABA Letter to the Ways and Means Committee re: ABA's support for repeal of the 1099 reporting provision - February 14, 2011ABA Comment Letter to IRS on Draft Form 8939 - February 8, 2011ABA Encourages CFPB Implementation Team to Refer Consumer Complaints to Appropriate Prudential Regulators - February 8, 2011ABA Comments on FinCEN Proposal to Require Non-Bank Mortgage Lenders to Comply with AML and File SARs - February 4, 2011Proposed Rule on Definition of the term "Fiduciary" under ERISA - February 3, 2011ABA Comments on Proposed Rule to Expand Consumer Protection Regulations, Reg Z - February 1, 2011ABA Comment on Statement on Legal Entity identification for Financial Contracts - January 31, 2011ABA Comment Letter to FASB - Effective Dates and Transition Methods - January 28, 2011ABA Challenges FDIC Overdraft Payment FIL-81-2010 - January 28, 2011Letter to NCUA on Proposal to Share TCCUSF's Expenses Equally - January 26, 2011ABA Comment Letter on ANPR revisions for the ADA Title III on Equipment and Furniture - January 24, 2011ABA Comment on Accessibility of Web Information and Services - January 24, 2011 ABA Comment on Authority To Designate Financial Market Utilities as Systemically Important - January 20, 2011Joint Comment Letter to DOL on Fiduciary Definition - January 19, 2011ABA Comment Letter to SEC Proposal on SOX Study per DFA - January 19, 2011Letter to FDIC on Proposed Rulemaking on Orderly Liquidation Authority Provisions in the Dodd-Frank Act - January 18, 2011ABA Comments on Risk Retention Provisions For Qualified Residential Mortgages - January 12, 2011 ABA: Revise 'Leveraged Loans' Definition in Large-Bank Assessment Proposal - January 11, 2011 ABA Comment on Conformance Period for Volcker Implementation - January 10, 2011President's Working Group Report on Money Market Fund Reform - January 10, 2011ABA Comment Letter on Repurchase Agreements - January 10, 2011ABA Comment Letter on Repurchase Agreements - January 10, 2011ABA Letter to FRB on Financial Statements for Bank Holding Companies - January 3, 2011FDIC Proposal on the Assessment Base and Assessment Rates - January 3, 2011FDIC Proposal on a New Large Bank Assessment Pricing Scheme - January 3, 2011 Return to top 2010 ABA Opposes Cross-Border Wire Reporting Requirement - December 29, 2010ABA Comment Letter on Interim Final Rule Amending Reg Z: Rules Regarding Appraisal Independence - December 27, 2010Joint Trade Comments in Response to HUD's Solicitation for Comments Re: Warehouse Lending - December 23, 2010ABA Urges FED To Calibrate Reg. Z Changes With Dodd-Frank Rules - December 23, 2010Joint Trade Letter to Fed on Reg Z (TILA) Reverse Mortgages - December 22, 2010ABA Comment Letter on Warehouse Lending - December 22, 2010ABA Comment on National Flood Insurance Reform Effort - December 17, 2010Letter to FDIC on Employee Compensation Criteria in Risk Assessment System - December 17, 2010ABA Comment Letter on Deferral of the Effective Date of Disclosures about Troubled Debt Restructurings in Update No. 2010-20 - December 14, 2010ABA Comment Letter on FASB Exposure Draft on Leases - December 14, 2010Letter to FinCEN: Proposal on Updates to the Suspicious Activity Report Database - December 14, 2010Request for the FDIC to Extend the Comment Period on its Large Bank Assessments Proposal - December 13, 2010 ABA and Financial Services Roundtable to SEC on Implementing Whistleblower provisions - December 10, 2010ABA Comment Letter on FASB TDR Proposal - December 8, 2010ABA Comment Letter on FASB TDR Proposal - December 8, 2010Joint Comment Letter on Comment Periods and Implementation of New Derivatives Regulations - December 7, 2010ABA Comments on Proposed Thrift Financial Report Changes - December 6, 2010ABA Comment Letter on IRS Draft Form W-9 Request for Taxpayer Identification Number and Certification - December 3, 2010ABA's Response to SEC Proposal on Short Term Borrowings - November 29, 2010 FDIC Plan to Manage its Insurance Fund Over the Long Run - November 24, 2010Comment on Regulation Z regarding Interest Rates and Payment Changes - November 23, 2010Proposal on Certain Orderly Liquidation Provisions of Dodd-Frank - November 18, 2010 Shareholder Approval of Executive Compensation, Golden Parachute - November 18, 2010ABASA Letter to SEC on Disclosure for Asset-Backed Securities - November 16, 2010 Issuer Review of Assets in Offerings of Asset-Backed Securities - November 16, 2010 Disclosure for Asset-Backed Securities Required by Section 943 of DFA - November 16, 2010 Letter to FTC on Mortgages Acts and Practices — Advertising Rule - November 15, 2010ABA's Response to IRS Request for Comments on the Foreign Account Tax Compliance Act - November 12, 2010ABA Letter on State Regulatory Registry Board's proposal to set fees in accordance with the SAFE Act - November 12, 2010Letter to State Regulatory Registry Board: Proposal to Set Fees, SAFE Act - November 12, 2010Comment Letter on Foreign Account Tax Compliance Act - November 12, 2010 Letter to Moody's re: New Money Market Fund Rating Methodology - November 10, 2010Joint Trade Letter on RESPA-TILA - November 10, 2010 Fraud adjustment and fraud prevention standard provisions of Section 1075of the Dodd Frank Act related to debit card interchange fees - November 8, 2010Authority to Require Regulation of Nonbank Financial Companies - November 5, 2010ABASA Comment on Dealer-Affiliated PACs Under G-37 - October 29, 2010 Alternatives to Use of Credit Ratings in Risk-Based Capital Guidelines - October 25, 2010 ABA Comment on Jumbo Loans - October 25, 2010ABA Comments on Mutual Fund Distribution Fees; 12b-1 Reform - October 25, 2010ABA Comment Letter to SEC on U. S. Proxy System - October 22, 2010 Unlimited Insurance for Noninterest-bearing Accounts for 2011-2012 - October 15, 2010ABA Comments on Private Transfer Fee Covenants Guidance - October 15, 2010ABA Supports FHFA Private Transfer Fee Proposal, Offers Suggestions - October 15, 2010ABA Comment Letter to IRS: Regulations Governing Practice - October 7, 2010Basel Committee Contingent Capital Proposal - October 1, 2010Comment Letter to NACHA: Pain Points in the Rules - September 30, 2010ABA Comment Letter: IRS Notice 2010-51 - September 29, 2010IRS Notice 2010-51: Information Reporting Under the Amendments to Setion 6041 for Payments to Corporations and Payments of Gross Proceeds and With Respect to Property - September 29, 2010IRS Proposal on Electronic Funds Transfer - September 22, 2010Overdraft Payment Programs and Consumer Protection - September 22, 2010Comment on Title VII of Dodd-Frank Act - September 20, 2010ABA Comment to FRB - Electronic Transfer - September 16, 2010HITECH Proposal to Modify HIPAA Privacy - September 13, 2010ABA Comment on Countercyclical Capital Buffer Proposal - September 10, 2010Letter to FASB on Fair Value Measurements and Disclosure Requirements - September 7, 2010ABA Comments on Agencies' CRA Hearings - August 31, 2010Classification and Measurement of Financial Assets and Liabilities - August 31, 2010ABA Comment Letter to FASB - Credit Impairment of Financial Assets - August 31, 2010ABA Comment Letter to FASB - Derivative Instruments and Hedging Activities - August 31, 2010Comment Letter on Brokers, Dealers and Investment Advisers - August 30, 2010ABA Comment Letter to DOL on 408(b)(2) Interim Final Rule - August 27, 20105f1f08f5e89b4aa391d4736db1266cc282310LettertoElizabethMurphyonInvestmentCompanyAdv.pdf - August 23, 2010Letter to SEC on Target Date Fund Issues and Bank Collective Funds - August 23, 2010Comments on Proposal to Convert More Federal Benefits to Electronic Delivery - August 16, 2010ABA Supports Modification of U.S. Currency to Accommodate the Blind - August 15, 2010ABA and ABASA Comment Letter to SEC on Asset-Backed Securities - August 3, 2010ABA Expresses Concerns About Expansive HUD Interpretive Rule - July 26, 2010ABA Comment Letter to FHFA on Housing GSEs Issue Guidance on PACE Loans - July 22, 2010Comment on FMS Proposal Amending the Automated Clearing House (ACH) System - July 13, 2010FDIC Proposal to Amend the Pricing of Premiums for Large Banks - July 2, 2010ABA and ABASA Comment Letter to FDIC on Securitization Safe Harbor - July 1, 2010ABA Comments on Children's Online Privacy Protection (COPPA) Rule - June 29, 2010ABA Comments on OTS proposal "Supplemental Overdraft Protection Guidance" - June 28, 2010 Return to top For comment letters filed before 2010, check our Archives. 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