ABA Comment Letters

Year 2012	Year 2008
Year 2011	Year 2007
Year 2010	Year 2006
Year 2009

Dodd-Frank Act developments are tagged .

2013

ABA: Revise Proposed Changes to CRA Q&As (5/17/13)
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
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
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 on CFPB's Request for Information on Campus Financial Products, March 18, 2013
ABA Comment Letter to IRS Regarding NII Tax, March 18, 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/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

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 Comment Letter, October 22, 2012
MBSD Supplement to Joint Trades Letter on Basel III, October 22, 2012
FSR and ABA S&L Holding Compan 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
- 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
- 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

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
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 Orderling 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

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 1075
of 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 Assests 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

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
- Deferred Tax Assets Historical Perspective Tools
Letter to FHFA to Serve Underserved Markets for Fannie and Freddie, September 18, 2009
ABA Comment Letter to IASB on Classification and Measurement, September 14, 2009
ABA Supports FinCEN MSB Proposal, Offers Suggestions, September 9, 2009
ABA Comment Letter to SEC on Money Market Fund Reform, September 8, 2009
ABA on Consolidation of Asset-Backed Commercial Paper Programs, September 2, 2009
ABA Comment on FinCEN Proposal Regarding Mutual Funds, September 2, 2009
ABA Comment Letter on IASB RFI on Expected Cash Flows, September 1, 2009
ABA on Guidelines for Furnishers of Info to Consumer Reporting Agencies, August 28, 2009
ABA on Possible AML Program for Non-bank Mortgage Lenders, August 20, 2009
ABA Comment Letter on Proxy Access Proposal, August 17, 2009
ABA on TARP Standards for Compensation and Corporate Governance, August 14, 2009
ABA Comment on Goodwill Net of Tax GAAP Issue, August 7, 2009
ABA Comment on Proposed rule on GSE Executive Compensation, August 4, 2009
ABA Comment on the Interagency Proposal to Revise CRA, July 30, 2009
ABA Comment on FTC's Mortgage Acts and Practices Rulemaking, July 29, 2009
Extension of the FDIC Transaction Account Guarantee Program, July 29, 2009
Letter to SEC on Custody of Funds Proposal, July 28, 2009
Letter to FTC on Mortgage Assistance Relief Services, July 15, 2009
ABA on Residential Mortgage Loans, Making Home Affordable Program, July 13, 2009
NACHA Proposal re: Direct Access Registration, July 10, 2009
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

2008

FDIC Proposal on Assessments, December 17, 2008
Amendments to Regulation SHO, December 16, 2008
Mortgage Servicing Accounts, December 15, 2008
ABA Comment Letter Follow-up re: Executive Compensation, December 12, 2008
Thrift Financial Report Schedules, December 1, 2008
FDIC Deposit Insurance Regulations; Revocable Trust Accounts, December 1, 2008
Treatment of Certain Claims on, or Guaranteed By Fannie and Freddie, November 26, 2008
Changes to Call Report , November 24, 2008
Treatment of Perpetual Preferred Stock, November 21, 2008
Reserve Requirements of Depository Institutions, November 21, 2008
Continuation of FHA Secure Advocacy Letter, November 19, 2008
Troubled Assets Relief Program (TARP), November 19, 2008
ABA Letter to FDIC Proposal on raisingAssessment Rates in 2009, November 17, 2008
SEC - Fair Value - SEC Study, November 13, 2008
ABA Letter to FASB on OTTI, November 13, 2008
FDIC Temporary Liquidity Guarantee Program, November 13, 2008
FASB - Fair Value - Delay Implementation FASB 157 and 141R , November 12, 2008
NACHA Proposal re: Authorizations and Returns, November 7, 2008
Economic Sanctions Enforcement Guidelines, November 05, 2008
Leverage Ratio Exemption, October 31, 2008
Money Market Mutual Funds, October 31, 2008
Reg W: Exception for Certain Securities Financing Transactions, October 31, 2008
Capital Adequacy Guidelines; Deduction of Goodwill Net of Deferred Tax Liability, October 30, 2008
Guarantee Program for Troubled Assets, October 28, 2008
Standardized Approach to Determine Risk-Based Capital, October 27, 2008
IRS on Filing Extension Proposal, September 29, 2008
Recordkeeping Requirements for Qualified Financial Contracts Rule, September 26, 2008
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

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 Propoal on Proposed Changes to Regulation B, June 29, 2007
Federal Reserve Proposal on Changes to Regulation E, June 29, 2007
Federal Reserve Proposal on Changes to Regulation DD, June 29, 2007
Federal Reserve Proposal on Changes to Regulation Z, June 29, 2007
ABASA Comment 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 Propsal on Small Loan Guidelines, February 1, 2007
Letter on Prohibited Transaction Exemption for the Provision of Investment Advice to IRA holders, January 30, 2007
ABA Makes Suggestions on Talent Amendment ("Payday Law"), January 23, 2007
ABA Says OTS' Proposed CRA Reg Alignment 'Unwarranted', January 23, 2007
Modification of the Market Risk Capital Rule, January 23, 2007
ABA Joint Talent Amendment Letter to DOD, January 5, 2007

2006

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
Proposed Interagency Statement on Sound Practices Concerning Complex Structured Finance Activities, June 15, 2006
Home Depot's Change in Bank Control Notice, June 6, 2006
Effect of FDIRA on Call Reports, May 22, 2006
Interim Rule Revising Deposit Insurance Regulations, May 22, 2006
Response To FinCEN Cross Border Transfer Survey, April 21, 2006
Suggested Improvements to SAR-DI, April 18, 2006
Letter to FASB on Fair Value Option, April 18, 2006
Mutual Fund Redemption Fees (22c-2), April 14, 2006
Executive Compensation and Related Party Disclosure, April 14, 2006
EGRPRA Burden Reduction: Prompt Corrective Action and Disclosure and Reporting of CRA-Related Agreements, April 3, 2006
Interagency Guidance on Concentrations in Commercial Real Estate, March 30, 2006
SEC Small Business Advisory Committee, April 3, 2006
Proposed Guidance on Nontraditional Mortgages , March 29, 2006
Proposed Amendments To NCUA "Underserved" Expansion Rules, March 27, 2006
Economic Sanctions Enforcement Procedures for Banking Institutions, March 13, 2006
Reg E Payroll Card Proposal, (due March 13; filed February 27, 2006)
ANPR on Revising Domestic Capital Adequacy Guidelines, January 18, 2006
Proposed Revisions to Community Reinvestment Act Questions and Answers, January 9, 2006
ABA Urges OCC to Make ML Risk Project Voluntary, January 9, 2006

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