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Joint Trades Letter on Reproposed Margin and Capital Requirements for Covered Swap Entities, November 24, 2014 ABA Comment Letter to Joint Agencies on Uncleared Swaps Margin, November 24, 2014 Joint Letter to DoD Requesting Joint Meeting re: Military Lending Act, November 18, 2014 Joint Letter to DoD Requesting Extension of Military Lending Act Proposal, November 18, 2014 ABA Comment to Department of Labor on Standards for Brokerage Windows in Participant-Directed Retirement Plans November 18, 2014 ABA Comment on Guaranteed Loanmaking and Servicing Regulations November 17, 2014 ABA and CBA Joint Comment on the Proposed Amendments to Regulation C (HMDA), November 10, 2014 ABA Comment on TILA-RESPA Disclosures, November 10, 2014 ABA Comment on CRA Q&As, November 7, 2014 Joint ABA/State Associations Letter re: CFPB Proposed Amendments to HMDA Reporting Data, October 29, 2014 Joint Trades Letter re: CFPB Proposed Amendments to HMDA Reporting Data, October 29, 2014 ABA on NACHA Request for Comment and Request for Information, Compliance and Operational Topics, October 24, 2014 ABA Comments to FHFA on Single Security Structure, October 13, 2014 Response to Basel Committee Consultative Document on Pillar 3 Disclosure Requirements, October 10, 2014 Joint Letter Requesting Comment Period Extension on Military Lending Act Proposal, October 8, 2014 ABA and BAFT Say Customer Due Diligence Proposal Too Costly for Banks, October 3, 2014 ABA Comments on NCUA Fixed Asset Ownership Proposal, September 26, 2014 ABA Supports FinCEN’s Imposition of Special Measure Against FBME, Offers Suggestions, September 22, 2014 ABA Comment on CFPB's Consumer Complaint Database, September 22, 2014 FDIC proposal on (1) measurement of counterparty exposures for the HCI scorecard and (2) custodial bank deduction from its assessment base, September 22, 2014 Joint Trades Letter re: Extension Request - Servicing Section of the FHA Single-Family Housing Policy Handbook, September 19, 2014 Joint Trades Letter on TILA RESPA Implementation, September 16, 2014 ABA Comment Letter on Mobile Financial Services, September 10, 2014 ABA Comments to FHFA on Guarantee Fees, September 8, 2014 ABA Request to FHFA on Extension to File re: FHLB Membership Requirements, September 4, 2014 Comment Letter to OCC on EGRPRA Review: Fiduciary Regulations, September 2, 2014 Comment Letter to OCC on Licensing, September 2, 2014 Comment Letter to OCC, FDIC and FRB on EGRPRA Review, September 2, 2014 Letter to MSRB on Proposed Rule G-44, August 26, 2012 Letter to MRSB on Proposed Revisions to Rule G-42, August 25, 2014 ABA Opposes CFPB's Debt Collection Survey, August 19, 2014 ABA Comment Letter to FRB on Midsize Bank Concerns, August 11, 2014 Joint Trades Letter to FRB on Capital Plan Rule, August 11, 2014 Letter to OCC on Integration of Licensing Rules, August 8, 2014 Letter to Treasury on Public Input on Development of Responsible Private Label Securities Market, August 8, 2014 ABA Comment to CFPB on Consumer Privacy Notices, July 14, 2014 Letter on Conceptual Framework for Financial Reporting - Chapter 8: Notes to Financial Statements, July 14, 2014 Letter to the Basel Committee relative to a consultative document on Pillar 3 disclosures, July 11, 2014 ABA Comments to CFPB on ATR-QM DTI Requirement & Small Creditor QM Exemption, July 7, 2014 Joint Trades Supplemental LCR Comment Letter, July 1, 2014 Joint Comment on Phone Survey Exploring Consumer Awareness of Credit Card Agreements, June 30, 2014 Comment Letter to NCUA on Associational Common Bond Requirements, June 20, 2014 Comment Letter on Leverage Ratio, June 13, 2014 Proposed Revisions to Eligible Guarantee Definition, June 13, 2014 Joint Comments on CFPB's Request for Information on Consumer Financial Behavior Study, June 12, 2014 ABA Comments on Minimum Requirements for Appraisal Management Companies, June 9, 2014 Trade Associations Support Temporary Exception in Remittance Proposal, June 6, 2014 ABA Comment Letter to DOL on Amendment to Section 408(b)(2), June 6, 2014 ABA Requests Additional Time to Comply with Flood Insurance for Other Residential Buildings, June 5, 2014 ABA Says Changing Weight or Dimensions of U.S. Coins too Costly for Banks, June 5, 2014 ABA Comments to CFPB on Cure Provisions under the Ability to Repay Rule, June 5, 2014 ABA Letter to IRS Re Unbundling of Trustee Fee Rule, May 30, 2014 Joint Trades Comment Letter on LCR Daily Calculation Requirement, May 19, 2014 ABA Says Further Discussions Needed in NACHA's Proposed Expansion of Addenda Records, May 16, 2014 Trade Associations Ask CFPB to Extend Reg P Comment Deadline, May 13, 2014 Joint Comment to HUD on FHA Prepayments and Elimination of Post-Payment Interest Charges, May 12, 2014 ABA Suggests Refinements to CFPB Debt Collection Study, May 6, 2014 Joint Trade Comment to Fed on Reg CC, Availability of Funds and Collection of Checks, May 2, 2014 Letter to MSRB on Draft Rule G-44 Supervisory and Compliance Obligations of Municipal Advisors, May 1, 2014 Joint Trades Comment Letter on FRB re Merchant Banking Activities, April 16, 2014 Joint Trades Letter to FRB re: Physical Commodities ANPR, April 16, 2014 Comment Letter re: Implementation Plans for the Homeowner Flood Insurance Affordability Act, April 15, 2014 Joint Trades Letter to OMB re Section408(b)(2) Guidance Requirement, April 11, 2014 ABA, CBA: Student Aid Rulemaking Casts Too Wide a Net, April 2, 2014 Letter to CFPB on Defining Larger Participants of the International Money Transfer Market, April 1, 2014 Joint Trades Comment Letter to OCC on Integration of 12 CFR Parts 30 and 170, March 28, 2014 Joint Trades Comment Letter to BCBS on Leverage Ratios, March 17, 2014 ABA Comment Letter on OFR Asset Management and Financial Stability Report, March 14, 2014 ABASA Letter to CFTC Regarding Cross-Border Swaps Guidance, March 10, 2014 ABA Comment Letter to MSRB on Fiduciary Duty, March 4, 2014 ABA Comment Letter on Volcker Rule Interim Final Rule on TruPS CDOs, March 3, 2014 Joint Comment Letter to CFPB's ANPR on Debt Collection, February 28, 2014 ABA Comment Letter on Interagency Addendum to Tax Allocation Policy Statement, February 26, 2014 Joint Trades Comment Letter on FDIC Single Point of Entry Release , February 18, 2014 ABA Comment on Payment System Risk Policy, February 10, 2014 ABA Comment on Regulation J, February 10, 2014 Groups Urge Delay on 'Know Before You Owe', February 7, 2014 Joint Comment on Complementary Activities, Merchant Banking Activities and Other Activities, February 7, 2014 Joint Comment Letter on the Proposed Interagency Policy Statement Establishing Joint Standards For Assessing the Diversity Policies and Practices of Regulated Entities, 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, 2014 Letter to FDIC, FRB, OCC on the Impact of Final Basel III Capital Rule on Subchapter S Banks, February 4, 2014 Joint Trades Comment Letter on Liquidity Coverage Ratio, January 31, 2014 ABA Corporate Trust Liquidity Coverage Ratio Coverage Comment Letter, January 31, 2014 ABA Liquidity Coverage Ratio Comment Letter, January 31, 2014 ABA Comment Letter on FASB Adoption of Final Impairment Model, January 24, 2014 ABA Comment Letter on IASB Conceptual Framework Paper, January 21, 2014 Comment on Improving ACH Network Quality by Reducing Exceptions, January 13, 2014 Comment 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, 2013 ABA Comment Letter to PCAOB Proposed Auditing Standards on Auditor Reports, December 11, 2013 Comment Letter to NCUA on Capital Planning and Stress Testing, December 17, 2013 ABA Comment on Fed's Payment System Consultation Paper, December 13, 2013 Joint Comment on Interagency Proposal to amend Flood Insurance Rules, December 6, 2013 ABA Comment Letter to Postal Regulatory Commission on Proposed Exigent Rate Increase, November 26, 2013 Joint Comment Letter on CFPB Amendments to Interim Final Servicing Rule, November 22, 2013 Complex Liquidity Report Comment Letter, November 18, 2013 ABA Comment Letter to FDIC Re Basel III, November 12, 2013 Comment on the Consultative Paper on AML/CFT Risk Management, October 31, 2013 ABA Comments on HUD-FHA Qualified Mortgage Definition, October 30, 2013 ABA Comments on Credit Risk Retention Proposed Rule, October 30, 2013 Joint Trade Association on Credit Risk Retention Re-Proposed Rule, October 30, 2013 Joint Trade Association Comment Letter on FRY 15, October 29, 2013 Letter to CFTC regarding Petition for Exemptive Relief and Interim No-Action Relief, October 25, 2013 ABA Letter to the Agencies Re: Removing "Eligible Guarantor" Definition from Basel III Rule, October 24, 2013 Joint Trades Comment Letter to OCC, FRB and FDIC Re: Regulatory Capital and Enhanced Supplementary Leverage Ratio Standards, October 21, 2013 Comment Letter to NCUA regarding Charitable Donation Account, October 21, 2013 Letter to CFPB on ABA Survey of Consumers Who Regularly Use Overdraft Protection Services, October 17, 2013 Proposed Changes for Basel III Capital in Call Report Schedule RC-R & Form FR Y-9 & FFIEC Form 101, October 11, 2013 Joint Trades FHFA Comments on GSE's 2014 Multifamily Scorecard, October 8, 2013 ABA Comment To CFPB on Overdraft Program Research, October 7, 2013 ABA Comment Letter on Insurance Contracts (ED), October 1, 2013 ABA Letter to Basel Committee on Banking Supervision Re Credit Risk Exposures, September 27, 2013 ABA 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, 2013 ABA/GFMA Joint Trades Comment Letter Re: Basel III Leverage Ratio Framework and Disclosure Requirements, September 20, 2013 ABA Comment to NACHA Re Clarification and Use of R03 and R04, September 20, 2013 ABA Letter to IRS Re Cost Basis Rules for Debt Instruments, September 18, 2013 ABA Letter to SEC Re Money Market Mutual Fund Proposal, September 17, 2013 ABA Letter Re CFTC Cross-border Guidance and Overseas Branches to the Treasury Department, September 6, 2013 ABA Letter Re CFTC Cross-border Guidance and Overseas Branches to the Prudential Regulators, September 6, 2013 ABA Comment Letter on Leases, August 28, 2013 Joint Trade Report of Selected Money Market Rates (FR 2420), August 28, 2013 FR Y-14 Data Collection Comment Letter, August 26, 2013 Letter to CFPB on Comment Request re: Generic Clearance for Consumer Complaint and Information Collection System, August 23, 2013 ABA/SIFMA Comment Letter Re IRS Draft Forms for IRAs, August 20, 2013 Comment on FTC's Proposed Amendment to Telemarketing Sales Rule, August 8, 2013 ABA Comment Letter to DOL re ANPR on Lifetime Income Illustrations, August 7, 2013 Joint Comment Letter on Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute Resolution Provisions in Credit Card Agreements, August 6, 2013 Joint Comment Letter on Consumer Credit Protections for Servicemembers, August 1, 2013 ABA Comment to CFPB on Mortgage Servicing, July 22, 2013 ABA Comment to CFPB on Mortgage Origination, July 22, 2013 Joint Comment to CFPB on Commercial Lending Dodd-Frank Appraisals Section 1474 Concerns, July 19, 2013 Joint Comment Letter Requesting Extension re DOL's Lifetime Income ANPRM, June 18,2013 ABA Comment Letter to FRB re Supervision and Regulation Assessments for BHCs and SLHCs with $50+ Billion and NBFCs Supervised by the Fed, June 14, 2013 ABA-ABASA Letter Re SEC RFI on Duties of Brokers, Dealers and Investment Advisers, July 5, 2013 ABA Letter to IRS re Timing of CP-2100 Notices for 2012 IRS Form 1099-K, Payment Card and Third Party Network Transactions, July 3, 2013 ABA Comment Letter on the BCBS Consultative Document, External Audits of Banks, July 2, 2013 ABA Comment Letter on the Exposure Draft ED/2013/3: Financial Instruments - Expected Credit Loses, July 1, 2013 ABA Comment Letter to NACHA on Clarification of Third Parties in the ACH Network , June 28, 2013 Joint Comment to FinCEN on Lebanese Exchange Houses as Primary Money Laundering Concern, June 24, 2013 Joint Comment Letter Requesting Extension re DOL's Lifetime Income ANPRM, June 18, 2013 ABA Comment Letter to FASB on the Exposure Draft Accounting for Investments in Qualified Housing Projects, June 17, 2013 ABA Comment Letter to FRB re Supervision and Regulation Assessments for BHCs and SLHCs with $50+ Billion and NBFCs Supervised by the Fed, June 14, 2013 ABA Comment Letter on Clearing Deadline for Category 2 Entities, June 8, 2013 Joint Trades Comment Letter Requesting Extension of CFTC Cross-Border Guidance, June 6, 2013 ABA Comment Letter on Proposed Amendments to the CFPB's Mortgage Servicing Rules, June 3, 2013 ABA Comment Letter to CFPB on Amendments to Mortgage Rules Under RESPA-TILA, June 3, 2013 ABA Comment on OCC/FDIC Guidance on Deposit Advance Products, May 30, 2013 ABA/ABIA Letter to FHFA on Lender Placed Insurance Proposal, May 28, 2013 ABA/ABIA Letter to CFPB on Credit Insurance Premium Delay, May 23, 2013 ABA: Revise Proposed Changes to CRA Q&As, May 17, 2013 ABA Comment Letter to FASB on the Exposure Draft: Recognition and Measurement of Financial Assets and Financial Liabilities, May 15, 2013 Comment Letter to Joint Agencies re Reporting Templates, May 14, 2013 ABA Comment Letter to FASB on the Exposure Draft: Financial Instruments - Credit Losses, May 14, 2013 ABA Comment Letter to IASB and FASB on the Financial Instruments Credit Loss Exposure Draft, May 14, 2013 ABA Comment Letter to CFPB on Proposed Amendments to 2013 Escrows Final Rule Reg. Z, May 3, 2013 ABA Joint Comment Letter to Fed re 165 FBO Proposal, April 30, 2013 Joint Comment Letter with The Clearing House, CBA, The Financial Services Roundtable, and ICBA on Call Report, April 22, 2013 Joint Comment Letter to FDIC, FRB and OCC re Call Report, April 22, 2013 ABA/ABASA Comment letter to FDIC on Insured Deposits NPR, April 19, 2013 Joint Statement to Working Group on Retirement - Tax Reform, April 16, 2013 Interagency Guidance on Leveraged Lending, April 11, 2013 ABA Letter to OCC on Notice and Request for Comment re: BSA/Money Laundering Risk Assessment, April 8, 2013 Comment Letter to NACHA on Compliance and Operational Topics, April 5, 2013 Joint Comment Letter on Proposed Revisions to FFIEC 009 and FFIEC 009a, April 1, 2013 ABA Letter to the IRS Re Type III Support Organizations, March 29, 2013 ABA Comment on FEMA's decision to rescind the Mandatory Purchase of Flood Insurance Guidelines, March 28, 2013 ABA Comments to FFIEC Guidance on the Use of Social Media, March 25, 2013 Joint Comment Letter to SDNY, March 22, 2013 Joint Comment on CFPB's Request for Information on Campus Financial Products, March 18, 2013 ABA Comment Letter to IRS Regarding NII Tax, March 18, 2013 Joint Association Comment Letter to the FRB Board, March 15, 2013 ABA Comments on QM and Ability to Repay Standards, February 25, 2013 ABA Comments on Points and Fees under the Ability to Repay Rule, February 25, 2013 ABA Letter to CFTC Regarding Petition for Exemptive Relief, February 23 ,2013 ABA/TCH Comment letter on Proposed Regs: IRS Truncated Tax ID Numbers on Payee Statements, February 21, 2013 Joint Comment Letter to FRB Regarding Data Collection, February 19, 2013 ABA Comment on Request for Information on Credit CARD Act's Impact, February 19, 2013 Joint Comment on CFPB Proposal on Trial Disclosures, February 15, 2013 ABA Comment Letter to FRB Regarding Scenario Development Policy, February 15, 2013 ABA Comment Letter to IRS Regarding 1099C Notice 2012-65, February 11, 2013 ABASA Comment Letter to FSA Regarding 'CP12-23 Depositor Preference', January 31, 2013 Joint Comment on Proposed Revisions to Remittance Rules, January 30, 2013 ABA Comment on Proposal to Amend the Definitions of Transmittal of Funds and Funds Transfer, January 24, 2013 FSOC MMF Reform Comment Letter, January 18, 2013 ABA Supports Proposed Delay of Effective Date of Remittance Rules, January 15, 2013 ABA Comment on CFPB Proposal to amend “ability to repay” requirement for credit card applications, January 7, 2013 Return to top 2012 ABA Comments on Exposure Draft Clarifying the Scope of Disclosures about Offsetting Assets and Liabilities, December 18, 2012 ABA Letter to Agencies on Finalizing Volcker Rule Proposal, December 17, 2012 ABA Comments to FHFA on State-Level Guarantee Fee Pricing for Fannie Mae-Freddie Mac, November 26, 2012 Letter to NCUA on Chartering and Field of Membership Manual for Federal Credit Unions, November 19, 2012 Joint ABA/CBA Comment Letter on Generic Clearance for Collection of Info on Compliance Costs, November 9, 2012 ABA Comments on COSO Proposal on Internal Control Framework, November 8, 2012 ABA Comments to CFPB Regarding Proposed Rule Amending RESPA-TILA Disclosures, November 6, 2012 ABA Mutual Banks Comment Letter re Basel III, October 26, 2012 ABA Comment to CFPB on Whether Maine, Tennessee Gift Card Laws Should be Preempted, October 22, 2012 ABA/SIFMA/FSR Basel III letter (complete), October 22, 2012 ABA/SIFMA/FSR Basel III Comment Letter, October 22, 2012 MBSD Supplement to Joint Trades Letter on Basel III, October 22, 2012 FSR and ABA S&L Holding Company Letter in Basel III, October 22, 2012 Comments on FR-Y15, October 19, 2012 ABA Comment on Remittance Transfer Rules, October 17, 2012 ABA Comment to CFPB on Pentagon Federal Credit Agreement Simplification Survey , October 17, 2012 Comment on Proposal re: Loan Originator Compensation and “No-Point, No-Fee” Mortgage Option, October 16, 2012 ABA Comments to CFPB on ECOA Amendments Concerning Appraisals, October 15, 2012 ABA Comments on Appraisals for Higher Risk Mortgage Loans, October 15, 2012 ABA Comment Letter to CFPB's TILA (Regulation Z) Mortgage Servicing Proposal, October 9, 2012 ABIA Comment Letter to CFPB’s RESPA (Regulation X) Mortgage Servicing Proposal, October 9, 2012 ABA Comment Letter to NACHA on P2P Payments, October 1, 2012 ABA Comment Letter on ABA FATCA Credit Card, September 26, 2012 ABA Comment Letter to NACHA on IAT Modifications, September 24, 2012 ABA Comment Letter to NACHA on Compliance and Operational Topics, September 24, 2012 ABA Comment Letter to FASB on Disclosures about Liquidity Risk and Interest Rate Risk, September 21, 2012 ABA, Trade Groups Reiterate QM Requirements, September 14, 2012 Joint Request to FFIEC for ASC Extension, September 14, 2012 Joint 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, 2012 ABA, Trade Groups Oppose Eminent Domain Proposals, September 7, 2012 ABA Comments on CFPB HOEPA Proposals, September 7, 2012 ABA, TCH, and FSR Comment Letter on CCAR, September 4, 2012 Comment on 'Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act', August 27, 2012 ABA Comment Letter 'Eligible Contract Participant (ECP) Definition', August 24, 2012 ABASA MSRB Financial Incentives Disclosure CL, August 16, 2012 ABA Comments to CFPB on Elderly Financial Abuse Prevention, August 20, 2012 ABA Comment Letter to CFTC on Proposed Exemption for Cooperatives, August 16, 2012 Joint Comments on MSRB Financial Incentives Disclosures August 16, 2012 Joint Comment to CFPB on Generic Clearance for Collection of Information on Compliance Costs, August 13, 2012 ABA Letter to NCUA on Maintaining Access to Emergency Liquidity, August 7, 2012 TCH, ABA, and FSR Comment Letter on OCC Lending Limits, August 6, 2012 ABA, The Clearing House Raise Concerns on FinCEN’s Proposed Special Measures Against CredexBank, July 30, 2012 ABA Comment Letter on Nonbank Supervision Risks, July 24, 2012 ABA Comment Letter on Electronic Funds Transfers, July 23, 2012 Comment on Notice of Proposed Policy Statement re: Disclosure of Consumer Complaint Data, July 19, 2012 ABA Comment Letter on Indemnification Asset, July 16, 2012 ABA Letter to IRS Commissioner on Conclusive Presumption of Worthlessness July 13, 2012 ABA Comments on CFPB Reopening of Proposed Amendments to Reg Z, July 9, 2012 Comment Letter to CFPB on Arbitration, June 22, 2012 Comment Letter on NACHA Security Framework, June 22, 2012 Joint Letter Requesting Extension on Basel III Comments, June 22, 2012 ABA Letter to IRS re FATCA and Foreign Trust, June 18, 2012 Comment Letter to FHFA on Draft Strategic Plan June 13, 2012 Comment Letter on FSA Farm Loan Program Proposal, June 12, 2012 ABA Comment Letter to FinCEN on Customer Due Diligence, June 11, 2012 Comment Letter on OCC STIFF Proposal, June 8, 2012 ABA Additional Comments on CFPB Regulatory Streamlining Notice, June 4, 2012 CFTC Letter Second Amendment to Effective Date, May 30, 2012 Comment Letter Dodd-Frank Section 165/166, April 30, 2012 ABA Comment Letter to FDIC & OCC re Section 165 Stress Testing Requirements, April 30, 2012 ABA Comment Letter to FRB regarding Enhanced Prudential Standards, April 30, 2012 Joint Trade Letter on StressTesting to the FDIC & OCC, April 30, 2012 ABA Recommends Changes to FATCA Proposal, April 30, 2012 ABASA Comment on Enhanced Prudential Standards, April 30, 2012 Comment to the Fed on Capital Plans; Proposed Agency Information Collection Activities, April 23, 2012 Comment Letter on Internal Revenue Service Notice 2012-6, April 20, 2012 Joint Comment on Retail Foreign Exchange Transactions, April 18, 2012 ABA Comments on CFPB Payday Lending Hearing, April 17, 2012 Joint 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 Joint Comments on "Know Before You Owe" Mortgage Loan Initiative, April 16, 2012 ABA Supports CFPB's Proposal on Privileged Bank Information, April 16, 2012 ABA Requests for Comment Extension on CFPB Inquiry on Overdraft Practices, April 10, 2012 ABA Comment on CFPB Remittance Rule, April 9, 2012 Joint Comment on CFPB Remittance Rule, April 9, 2012 ABA Comments on Proposal to Update Internal Control Framework, March 16, 2012 Supplemental Comment Letter on Volcker Rule, March 9, 2012 ABA Comment on CFPB's Proposed Prototype Credit Card Contract, March 7, 2012 Comment on Assessment of Fees on Large Bank Holding Companies and Nonbank Financial Companies Supervised by the Federal Reserve Board, March 5, 2012 Joint Comment Letter from ABA, SIFMA, FSR, IIB, and The Clearing House, March 2, 2012 ABA Comment on CFPB Regulatory Streamlining, March 5, 2012 Treatment of Unrealized Gains and Losses Under the Basel III Capital Framework, March 1, 2012 ABA Comment Letter to IRS re Cost Basis, February 23, 2012 Comment on Investments in Corporate Debt by Savings Associations, February 21, 2012 Comment re: Rule Extending Regulatory Relief to all Federal Credit Unions, February 21, 2012 ABA Comment Letter on Investment Companies, February 15, 2012 Further Definition of Swap Dealer, February 14, 2012 ABASA 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 ABA Comment Letter re: Volcker Rule Proposal, February 13, 2012 ABA Letter re: Section 619 of DFA, Proprietary Trading - Hedge Funds and Private Equity, February 13, 2012 Joint Trades Volcker Comment Letter - Hedge Funds, February 13, 2012 (See Supplemental Comment Letter, March 9, 2012) Joint Trades Volcker Comment Letter - Proprietary Trading, February 13, 2012 Extension Request: Notice of Streamlining Project, February 10, 2012 ABA Comment Letter on Principal versus Agent Analysis, February 10, 2012 ABA Comments on FHLBs Community Support Amendments, February 8, 2012 ABA Comment on NPR re: Risk-Based Capital Guidelines, February 3, 2012 ABA Comment on Disclosure of Certain Credit Card Complaint Data, January 30, 2012 ABA Comment on Imposition of Special Measure Against Iran, January 27, 2012 ABA Comment on Proposed Revisions to the FR Y-9C, January 20, 2012 ABA Comment on Consolidated Reports of Condition and Income (Call Report), January 20, 2012 Comment to NCUA on Maintaining Access to Emergency Liquidity, January 18, 2012 (See Addendum, January 25, 2012) Comments regarding Proposed Rulemaking on the "Discriminatory Effects Standard" of the Fair Housing Act, January 17, 2012 ABA 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, 2011 Comment on OCC Proposal to Remove Ratings from Non-Capital Rules, December 29, 2011 ABA Comment on Standard Flood Hazard Determination Form, December 21, 2011 ABA Comment on the Federal Housing Agency's (FHFA) Alternative Mortgage Servicing Compensation Discussion Paper, December 20, 2011 Letter to FSOC on Nonbank Financial Companies, December 19, 2011 ABA Comment on Regulation J Regarding Collection of Checks, December 19, 2011 ABA Comment on Regulation D to Simplify the Administration of Reserve Requirements, December 19, 2011 ABA Comments on FinCEN CMIR Proposal, Definition of Monetary Instrument, December 16, 2011 Letter to NACHA re: Expedited Processing and Settlement, December 12, 2011 Risk-Based Capital Guidelines; Alternatives to Credit Ratings, December 9, 2011 ABA Comments to CFPB on RESPA-TILA Integration, December 9, 2011 ABA Comment Letter on the Concept Release on Auditor Independence and Audit Firm Rotation (Concept Release), December 9, 2011 ABA Letter to IRS Re Section 67(e) Proposal, December 6, 2011 ABA Comment: Guidance and Proposed Revisions on Flood Insurance Q&As, December 1, 2011 Joint Comment on Extension on Volcker Rule Proposed Regulations, November 30, 2011 ABA 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, 2011 ABA Comment on FinCEN's Proposal: Mandatory E-filing by June 2012, November 15, 2011 Re-Proposal of Shelf Eligibility Conditions for Asset-Backed Securities, November 10, 2011 Comment to FSB on the Consultative Document Understanding Financial Linkages, November 7, 2011 Comment to FRB on Capital Plans: Proposed Agency Information Collection Activities, November 7, 2011 Comment to IRS on Guidance of Portability of Deceased Spousal Unused Exclusion Amount, November 7, 2011 Comment on Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant", November 3, 2011 Joint Comment on Proposed New Information Collection for Savings and Loan Holding Companies (SLHCs), November 1, 2011 ABA Comments on FCS in FHA Mortgage Insurance Programs, October 21, 2011 Letter to the Agencies on a Supervisory Presumption that Every Exposure to an Investment Fund Warrants Securitization Treatment Unless Proven Otherwise, October 18, 2011 ABA Comment to FCC Re: Petitions for Declaratory Ruling Concerning the Telephone Consumer Protection Act Rules October 10, 2011 ABA Comment Letter to IRS on Credit Union Common Bond Requirement, October 10, 2011 ABA Letter to Fed on G20 High-Level Principles on Financial Consumer Protection, October 10, 2011 Comment to NCUA: Proposed Amendments to Corporate Credit Unions, October 5, 2011 Joint Comment on Debit Card Fraud Prevention Adjustment, September 30, 2011 Additional Comments on End-User Exception to Mandatory Clearing of Swaps and Security-Based Swaps, September 30, 2011 ABA Comment Letter to PCAOB Concept Release on Auditor Reports, September 30, 2011 Joint Comment to CFPB on Disclosure of Records and Information, September 26, 2011 Joint Comment re: Consolidated Reports of Condition and Income, September 26, 2011 Joint Comment to CFPB on Interim Final Rules on Investigations, and Interim Final Rules of Practice Governing Adjudication Proceedings, September 26, 2011 Letter to CFPB on Alternative Mortgage Transaction Parity (Reg D), September 22, 2011 Letter to IRS Asks for Penalty Waiver on Merchant Reporting Rules, September 20, 2011 Letter regarding disposition of REO properties held by Fannie, Freddie and FHA, September 15, 2011 ABA Letter to OECD re: High-level Principles on Financial Consumer Protection, August 31, 2011 Comment on Consultative Document: Globally systemically important banks: Assessment methodology and the additional loss absorbency requirement, August 26, 2011 ABA to the Agencies: Don't Add New Overdraft Program Requirements, August 24, 2011 ABA Comments on NACHA Pain Points Rules--Phase Two, August 19, 2011 Comment on Credit Union Service Organizations (CUSO), August 16, 2011 Comment on Defining Larger Participants in Consumer Financial Products & Services Markets, August 15, 2011 Capital Requirements of Swap Dealers and Major Swap Participants, August 12, 2011 ABA Comments on CFPB's New Mortgage Forms, August 10, 2011 ABA Urges OCC to Withdraw Proposed Consumer Credit Product Guidance, August 4, 2011 Joint Comment on Capital Plans, Regulation Y, August 5, 2011 Inter-agency Proposal on Capital Planning for the Largest Banking Firms, August 5, 2011 Comment Letter on Adoption of International Financial Reporting Standards, August 1, 2011 ABA Urges OMB to Withhold General Approval of CFPB Consumer Response Intake Fields, August 1, 2011 Comment on Proposal to Establish Credit Risk Retention Requirements, August 1, 2011 Associations Offer Suggestions on Stress Testing Proposed Guidance, July 29, 2011 Comment on Proposed Rule Amending Reg Z: Ability-To-Repay Requirements, July 22, 2011 ABA Addresses Concerns with Fed's Proposal on Remittances, July 22, 2011 ABA/ABASA re: Margin and Capital Requirements for Swaps, July 11, 2011 ABA Comment to IRS on Credit Unions (associated common bonds), July 8, 2011 Comment on Proposed Order regarding Effective Date for Swap Regulation, July 1, 2011 ABA Seeks Comment Extension on Overdraft Guidance, June 27, 2011 Comment re: OTS Integration, ABA Backs OCC on Pre-emption Standard, June 27, 2011 ABA Comment Letter to NACHA on Risk Management Enhancements, June 24, 2011 ABA Comment Letter to OCC/FDIC re: Retail Foreign Exchange Transactions, June 20, 2011 Joint Trades Letter requesting extension of Comment Period for Capital and Margin Requirements for Covered Swap Entities, June 17, 2011 Joint Trades Letter requesting Relief Under Section 774 of the DFA June 10, 2011 Comment on Proposed Rule Implementing the Resolution Plan ("living wills") section 165(d) of Title I of DFA, June 10, 2011 ABA Comment on NACHA Corporate Account Takeover, June 10, 2011 ABA letter requesting clarifications about FinCEN's FBAR Final Rule, June 10, 2011 Comment 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, 2011 Joint Comment on Foreign Exchange Swaps and Foreign Exchange Forwards, June 3, 2011 ABA/ABASA to CFTC on Reopening and Extension of Comment Periods for Swaps Rulemaking, June 3, 2011 Joint ABA/BAFT-IFSA Comment on FinCEN's CISADA Proposed Rule, June 1, 2011 Comment on Assessment Rate Adjustment Guidelines for Large and Highly Complex Institutions, May 31, 2011 Comment on Incentive-Based Compensation Arrangements, May 31, 2011 ABA Comment Letter on Draft Mortgage Disclosure Forms, May 27, 2011 ABA Comment Letter to IRS Requesting to Extend Truncation Program to All TIN Types, May 24, 2011 Comment on Garnishment of Accounts Containing Federal Benefit Payments, May 24, 2011 Comment to SEC re: Missing Securityholders, Rule 17Ad-17, Transfer Agents', Brokers', and Dealers' Obligation to Search for Lost Securityholders, May 23, 2011 ABA Comment on NPR Regarding the Risk Management Standards of Certain Financial Market Utilities, May 19, 2011 ABA Comment on Proposed Regulatory Reporting Revisions to the Call Report, TFR, and FFIEC Forms 002 and 002S, May 16, 2011 ABA Comment Letter on Large Bank Reporting: Subprime and Leverage Loans, May 16, 2011 Joint Letter to FRB re: Proposed Rulemaking implementing the repeal of the prohibition against payment of interest on Demand Deposits (Regulation Q), May 16, 2011 Joint Letter to FDIC re: Proposed Rulemaking on interest on deposits and deposit insurance coverage (Regulation Q), May 16, 2011 Joint 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 ABA Letter to Congress to educate them about Mutual Community Banks, May 3, 2011 Comment on Core and Brokered Deposit Study Mandated by the Dodd-Frank Act, May 2, 2011 ABA Comment Letter on the Board's Proposal Regarding Mandatory Escrow and Disclosures on Higher Priced Mortgage Loans (HPMLs), May 2, 2011 Comment to NCUA on Net Worth and Equity Ratio Proposed Rule, April 29, 2011 ABA Comment Letter on the IASB Exposure Draft: Offsetting Financial Assets and Financial Liabilities/FASB Exposure Draft: Offsetting, April 28, 2011 ABA Comment Letter to FASB on Selected Issues about Hedge Accounting, April 26, 2011 ABA Comment on Federal Government Participation in the Automated Clearinghouse, April 25, 2011 Comment re: Proposed Rules on Risk-Based Pricing Notices (Regulation V), April 13, 2011 ABA Comment Letter to FRB on Equal Credit Opportunity Act, April 13, 2011 Letter to FDIC on Amendments to Deposit Insurance Regulations, April 12, 2011 ABA Comment: Public Hearing on Definition of Fiduciary, April 12, 2011 ABA Comment on Proposal to Standardize Holding Company Reporting, April 11, 2011 ABA Comment on Cost of Funds Indices (Notice of Intent to Discontinue), April 11, 2011 Proposal to Require Call Report Adoption, April 11, 2011 Exemption From Tax on Corporations, Certain Trusts, Etc. (Revenue Ruling 2011-1), April 11, 2011 ABA Comment on Draft MSRB Rule G-36 (On Fiduciary Duty of Muni Advisors) , April 11, 2011 ABA Comment Letter on Summary of Deposits for OTS Institutions, April 11, 2011 ABA/The Clearing House Letter on Basel II Pillar 3 Concerns, April 11, 2011 ABA Comment Letter to NACHA on IAT Modifications and Refinements, April 8, 2011 ABA/CH/IIF/ISDA/SIFMA Letter on the Agencies Market Risk Capital Proposal, April 11, 2011 Proposed Change in the Rules Relating to the Taxation of Foreign Corporations, April 8, 2011 ABA Comment Letter to DOL on Reducing Regulatory Burden April 8, 2011 IRS Proposed Regulations on Reporting Interest to Nonresident Alien Individuals, April 7, 2011 ABA 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, 2011 ABA Comment on FDIC Interim Rule Implementing the Orderly Liquidation Authority Provision of the Dodd-Frank Act , March 28, 2011 ABA Offers Suggestions to FinCEN re: CTR and DOEP Proposed Data Fields, March 28, 2011 ABA Comment on NACHA's ACH Security Framework, March 25, 2011 ABA Comment on Membership Requirements for Members of FHLBs, March 17, 2011 ABA Comment to OCC on Loans in Areas Having Special Flood Hazards, March 15, 2011 ABA Comment Letter to IRS on Credit Unions, March 10, 2011 ABA Letter to Congress on NRA Regulations, March 10, 2011 Comments regarding FSOC's Study & Recommendations Regarding Concentration Limits on Large Financial Companies, March 10, 2011 ABA Comment to IASB on Exposure Draft: Hedge Accounting, March 9, 2011 Joint Comment on Revised Interim Final Regulation Implementing Provisions in the Mortgage Disclosure Improvement Act, February 28, 2011 ABA Comment on Risk-Based Capital Floor Proposal, February 28, 2011 ABA Comment on MSRB Pay to Play Rule for Municipal Advisors, February 25, 2011 ABA Addresses Burden BCFP Will Impose on the Banking Industry, February 24, 2011 Comment on NPRM To Require Supervision and Regulation of Certain Nonbank Financial Companies, February 24, 2011 Joint Comment Letter to CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties, February 22, 2011 ABA/ABASA Comment to SEC/CFTC on definition of "Swap Dealer", February 22, 2011 Comment to SEC/CFTC on End-User Exception to Mandatory Clearing of Swaps, February 22, 2011 ABA Comment on SEC Registration of Municipal Advisors, February 22, 2011 ABA Comment on Debit Card Interchange Fees, February 22, 2011 Joint Comment on Debit Card Interchange Fees, February 22, 2011 ABA Comment on NCUA Proposed Rule on Accuracy of Advertising, February 22, 2011 ABA 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, 2011 ABA Letter to the Federal Reserve and other Agencies Regarding the Potential Treatment of Exposures to Investment Companies as Securitization Exposures, February 15, 2011 Comment to NCUA on Sample Income Data to Meet the Low-Income Definition, February 14, 2011 ABA Letter to the Ways and Means Committee re: ABA's support for repeal of the 1099 reporting provision, February 14, 2011 ABA Makes Recommendations Regarding the Future of Government Sponsored Enterprises, February 9, 2011 ABA Encourages CFPB Implementation Team to Refer Consumer Complaints to Appropriate Prudential Regulators, February 8, 2011 ABA Comment Letter to IRS on Draft Form 8939 February 8, 2011 ABA Comments on FinCEN Proposal to Require Non-Bank Mortgage Lenders to Comply with AML and File SARs February 4, 2011 Proposed Rule on Definition of the term "Fiduciary" under ERISA, February 3, 2011 ABA Comments on Proposed Rule to Expand Consumer Protection Regulations, Reg Z, February 1, 2011 ABA Comment on Statement on Legal Entity Identification for Financial Contracts, January 31, 2011 ABA Challenges FDIC Overdraft Payment FIL, January 28, 2011 ABA Comment Letter to FASB - Effective Dates and Transition Methods, January 28, 2011 ABA Comment on Accessibility of Web Information and Services, January 24, 2011 ABA Comment Letter on ANPR revisions for the ADA Title III on Equipment and Furniture January 24, 2011 ABA Comment on Authority To Designate Financial Market Utilities as Systemically Important, January 20, 2011 ABA Comment Letter to SEC Proposal on SOX Study per DFA, January 19, 2011 Joint Comment Letter to DOL on Fiduciary Definition January 19, 2011 ABA Comment on NPR Implementing Certain Orderly Liquidation Provisions of the Dodd-Frank Act, January 18, 2011 ABA: Revise 'Leveraged Loans' Definition in Large-Bank Assessment Proposal January 13, 2011 ABA Comment on Risk Retention Provisions For Qualified Residential Mortgages, January 12, 2011 ABA Comment on Conformance Period for Volcker Implementation, January 10, 2011 President's Working Group Report on Money Market Fund Reform, January 10, 2011 ABA Comment Letter on Repurchase Agreements, January 10, 2011 ABA Letter to FRB on Financial Statements for Bank Holding Companies, January 3, 2011 FDIC Proposal on the Assessment Base and Assessment Rates, January 3, 2011 FDIC 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, 2010 ABA Comment Letter on Interim Final Rule Amending Reg Z: Rules Regarding Appraisal Independence, December 27, 2010 ABA Urges FED To Calibrate Reg. Z Changes With Dodd-Frank Rules, December 23, 2010 Joint Trade Comments in response to HUD's solicitation for comments re: Warehouse Lending, December 22, 2010 Joint Trade Letter to Fed on Reg Z (TILA) Reverse Mortgages, December 22, 2010 ABA and Financial Services Roundtable to SEC on Implementing Whistleblower provisions, December 17, 2010 ABA Comment on National Flood Insurance Reform Effort, December 17, 2010 Letter to FinCEN: Proposal on Updates to the Suspicious Activity Report Database, December 14, 2010 ABA Comment Letter on FASB Exposure Draft on Leases, December 14, 2010 ABA Comment Letter on Deferral of the Effective Date of Disclosures about Troubled Debt Restructurings in Update No. 2010-20, December 14, 2010 Request for the FDIC to Extend the Comment Period on its Large Bank Assessments Proposal, December 13, 2010 ABA Comment Letter on FASB TDR Proposal, December 8, 2010 Joint Letter to SEC and CFTC on Implementation of Derivatives Regulations, December 6, 2010 ABA Comments on Proposed Thrift Financial Report Changes, December 6, 2010 ABA Comment Letter on IRS Draft Form W-9 Request for Taxpayer Identification Number and Certification, December 3, 2010 ABA's Response to SEC Proposal on Short Term Borrowings, November 29, 2010 Letter to Treasury on Foreign Exchange Swaps and Forwards, November 29, 2010 FDIC Plan to Manage its Insurance Fund Over the Long Run, November 24, 2010 Comment on Regulation Z regarding Interest Rates and Payment Changes, November 23, 2010 Proposal on Certain Orderly Liquidation Provisions of Dodd-Frank , November 18, 2010 Shareholder Approval of Executive Compensation, Golden Parachute, November 18, 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, 2010 Letter to State Regulatory Registry Board: Proposal to Set Fees, SAFE Act, November 12, 2010 Joint Trade Letter on RESPA-TILA, November 10, 2010 Comment Letter on Foreign Account Tax Compliance Act, November 12, 2010 Letter to Moody's re: New Money Market Fund Rating Methodology, November 11, 2010 Fraud adjustment and fraud prevention standard provisions of Section 1075of the Dodd Frank Act related to debit card interchange fees, November 8, 2010 Authority to Require Regulation of Nonbank Financial Companies, November 5, 2010 ABASA letter to FSOC on "Volcker Rule", November 4, 2010 ABA letter to FSOC on "Volcker Rule", November 3, 2010 ABASA Comment on Dealer-Affiliated PACs Under G-37, October 29, 2010 ABA Comment on Jumbo Loans, October 25, 2010 Comment on Alternatives to External Credit Ratings in OTS Regs, October 25, 2010 Comment on Alternatives to External Credit Ratings in OCC Regs, October 25, 2010 Alternatives to Use of Credit Ratings in Risk-Based Capital Guidelines, October 25, 2010 ABA Comments on Mutual Fund Distribution Fees; 12b-1 Reform, October 25 2010 ABA Comment Letter to SEC on U. S. Proxy System October 22, 2010 ABA Supports FHFA Private Transfer Fee Proposal, Offers Suggestions, October 15, 2010 ABA Comments on Private Transfer Fee Covenants Guidance, October 15, 2010 Unlimited Insurance for Noninterest-bearing Accounts for 2011-2012, October 15, 2010 Letter to SEC on Temporary Registration of Municipal Advisors, October 13, 2010 ABA Comment Letter to IRS: Regulations Governing Practice, October 7, 2010 ABA Comment Letter: IRS Notice 2010-51, September 29, 2010 Basel Committee Contingent Capital Proposal, October 1, 2010 Comment Letter to NACHA: Pain Points in the Rules, September 30, 2010 Overdraft Payment Programs and Consumer Protection, September 22, 2010 IRS Proposal on Electronic Funds Transfer, September 22, 2010 Comment on Title VII of Dodd-Frank Act, September 20, 2010 ABA Comment to FRB - Electronic Transfer, September 16, 2010 HITECH Proposal to Modify HIPAA Privacy, September 13, 2010 ABA Comment on Countercyclical Capital Buffer Proposal, September 10, 2010 Letter to FASB on Fair Value Measurements and Disclosure Requirements, September 7, 2010 Classification and Measurement of Financial Assets and Liabilities, August 31, 2010 ABA Comment Letter to FASB - Credit Impairment of Financial Assets, August 31, 2010 ABA Comment Letter to FASB - Derivative Instruments and Hedging Activities, August 31, 2010 ABA Comments on Agencies' CRA Hearings, August 31, 2010 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 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, August 18, 2010 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 Letter to Basel: 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 Comment Letter to IRS on Alternative Approach to Foreign Address Exception, May 27, 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 Letter to Basel regarding International Framework for liquidity risk measurement, April 15, 2010 Letter to Basel regarding Strengthening the resilience of the banking sector, April 15, 2010 ABA on 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 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 Return to top 2009 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 Letter to FHFA on 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 (See Deferred Tax Assets Historical Perspective Tools) ABA Comment: Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance, September 21, 2009 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 SAFE Act Rule that would Require Loan Originators to Register with 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 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 Comment on Regulation Z Proposal which applies to Open-end credit plans, June 4, 2009 NACHA Customer Service Telephone Number RTI, May 28, 2009 ABA and CBA Comment on Regulation Z, HEOA, May 26, 2009 Interim final rule on Capital Classifications for the Federal Home Loan Banks, May 18, 2009 Letter to BCBS and IADI on 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 Return to top 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 raising Assessment 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 IRS Ban on the Use of Logos on Substitute Forms – Rev. Proc. 2008-36 September 17, 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 ADA Letter, Nondiscrimination on 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 Letter to FDIC re: Certificate of Deposit Account Registry Services , July 29, 2008 Implementation Concerns with IRS Automatic Contribution Proposal, July 25, 2008 FDIC's Financial Education Programs, July 23, 2008 FDIC National Unbanked and Underbanked Household Survey, July 18, 2008 Comment on Board's Regulation Z 2007 Open-end Credit Proposal, July 18, 2008 Regulation DD Truth in Savings Proposal on costs associated with overdrafts, July 18, 2008 ABA Comment on NCUA Low-Income Definition Proposal, July 2, 2008 ABA Opposes NCUA's Proposed Rule allowing credit unions to invest in 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 Proposed Reporting Requirements for Basel II Advanced Approaches Banks, February 25, 2008 Letter to European Banking Supervisors: 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 Return to top 2007 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 21, 2007 Elimination of IFRS to GAAP Reconciliation, September 21, 2007 Letter to FASB on Proposed DIG E23, September 21, 2007 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 Proposal 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 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 Joint Letter to FinCEN CBEFT Feasibility Study, March 5, 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 Proposal 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 Return to top 2006 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 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, 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 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) Financial Institution Trade Associations Join to Comment on USAPA 312 Proposal for EDD, March 6, 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 Return to top Go to ABA Testimony. 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