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ABA: The American Bankers Association

Phoebe Papageorgiou

Vice President, Trust Policy

Phoebe oversees the advocacy efforts of the ABA’s Trust Counsel Committee, Trust Taxation Committee, IRA Steering Committee, and Collective Funds Task Force. Her portfolio includes issues related to trust and wealth management services, fiduciary regulations and duties, tax reporting and preparation, investments, and bank custody services. Phoebe is a frequent speaker on bank fiduciary matters at ABA and state bankers associations’ wealth management and trust conferences, as well as similar events at other financial and legal associations. Prior to joining ABA in 2005, Phoebe worked for the U.S. Department of the Treasury in the Office of Domestic Finance. She received her law degree from The George Washington University Law School and her undergraduate degree from Carnegie Mellon University.
  • Comment Letter
    Letter to SEC on Outsourcing by Investment Advisers

    December 27, 2022

    ABA urges the SEC to minimize the burdens of the proposal on banks and bank-affiliated RIAs, better align the proposal with existing bank third-party due diligence and oversight obligations, and adopt specific recommendations if the SEC decides to proceed with a final rule.

  • Podcast
    Why Banks Should Invest in Digital Wealth Management

    November 17, 2022

    Unifimoney is a multi-asset digital wealth management platform for community banks and credit unions offering the trading options of over 80 cryptocurrencies, passive and active investing in over 10,000 stocks and ETF's and precious metals.

  • Letter to Congress & Regulators
    Letter to SEC on Notice of Assumption or Termination of Transfer Agent Services

    July 05, 2022

    ABA urges the SEC to clarify that Rule 17Ad-16 only requires a Notice with the Depository Trust and Clearing Corporation (DTCC) when (1) the filing transfer agent ceases to perform transfer agent services to an issuer, (2) the filing transfer agent is the successor to a previous transfer agent, or (3) there is a change of a transfer agent’s name or address.

  • Comment Letter
    Letter to IRS on Required Minimum Distributions

    May 25, 2022

    Some of the proposed changes are helpful to the industry and the clients they serve, in particular the clarifying rules for conduit trusts making them easier to administer, as well as the changes for 403(b) plans to conform their regulations to those of other retirement plans. However, other aspects of the proposed amendments would present compliance and other challenges.

  • Comment Letter
    Letter to SEC on Money Market Fund Reforms 2022

    April 11, 2022

    We urge the SEC to allow government MMFs to decide, based on its determination of the needs and characteristics of its investors, whether reverse distribution mechanism or floating NAV is the most appropriate way to manage the effects of negative interest rates.

  • Comment Letter
    Letter to SEC on Reporting of Securities Loans

    January 07, 2022

    While we understand the statutory and policy impetus for further transparency, we strongly urge the SEC to take a measured approach to the proposed rule that allows for full public consideration and commentary, in order to define a disclosure regime that meets the SEC's objectives, while avoiding unnecessary burdens on market participants and minimizing unintended consequences.

  • Comment Letter
    Simplification of Deposit Insurance Rules

    October 04, 2021

    The American Bankers Association, Bank Policy Institute, and Mortgage Bankers Association (collectively, the Associations) appreciate this opportunity to comment on the proposal from the Federal Deposit Insurance Corporation (FDIC) to simplify certain deposit insurance regulations. The Associations and our members agree that the proposed amendments to 12 CFR 330.10, 13, and 7(d), for deposit accounts of revocable trusts, irrevocable trusts, and mortgage servicing, respectively, will help simplify these complex rules.

  • Comment Letter
    Letter to FDIC on Part 370 Compliance Challenges and Requested Relief

    September 16, 2021

    All covered institutions continue to encounter major challenges in obtaining complete information from deposit owners that fail to respond to inquiries in timely manner or at all. We raise two particular challenges and urge actions the FDIC can take to support compliance with the rule.

  • Comment Letter
    Letter to FSB on the Policy Proposals to Enhance Money Market Fund Resilience

    August 16, 2021

    We appreciate the importance of examining the role and structure of MMFs in an effort to ensure market stability and the FSB's measured approach in considering the array of policy options. We take this opportunity to share comments on MMFs in the United States and principles for policy makers to consider in any reform efforts.

  • Podcast
    Tax Policy in a Democratic Washington

    February 24, 2021

    Jim Febeo from Fidelity Investments and Phoebe Papageorgiou from ABA discuss tax policy at the 2021 Wealth Management and Trust Conference

  • Comment Letter
    ABA Letter to OCC on Collective Investment Funds

    September 14, 2020

    ABA commented on the OCC's interim final rule on prior notice periods for withdrawals from collective investment funds that are invested in real estate or assets not readily marketable. Among other things, ABA urged the OCC to align the regulation with previous OCC guidance and make it a more principles-based set of requirements that defers to fiduciary considerations.

  • Comment Letter
    ABA Letter to DOL on ESG Investments in Plans Proposal

    July 30, 2020

    The American Bankers Association (ABA) appreciates this opportunity to comment on the Department of Labor's proposal, Financial Factors in Selecting Plan Investments, that amends existing regulations governing the investment duties of fiduciaries under the Employee Retirement Income Security Act of 1974 (ERISA). According to the release, the Department seeks to 'confirm that ERISA requires plan fiduciaries to select investments and investment course of action based solely on financial considerations relevant to the risk-adjusted economic value of a particular investment or investment course of action.'

  • Comment Letter
    ABA Comments on IRS Proposal on Trust and Estate Deductions

    June 25, 2020

    The American Bankers Association (ABA) appreciates this opportunity to comment on the Internal Revenue Services (IRS) proposed rule under section 67(g) of the Internal Revenue Code (IRC).

  • Comment Letter
    ABA Supports OCC Guidance for Short-Term Investment Funds

    May 11, 2020

    In response to ABA outreach, the OCC issued guidance providing additional flexibility to the rules governing STIFs, bank-managed funds for fiduciary clients that are similar to money market mutual funds.

  • Comment Letter
    ABA Comments to OCC on Licensing Amendments

    May 04, 2020

    ABA Letter to the OCC's Notice of Proposed Rulemaking, Licensing Amendments.

  • Comment Letter
    ABA Letter to SEC re Proposed Amendments to the Accredited Investor Definition

    March 16, 2020

    The American Bankers Association (ABA) appreciates this opportunity to comment on the Securities and Exchange Commission’s (Commission or SEC) proposed rule amending the “accredited investor” definition in Regulation D and “qualified institutional buyer” (QIB) definition in Rule 144A.

  • Letter to Congress & Regulators
    Letter to IRS re: EIN Application Process for Trusts and Estates

    February 07, 2020

    The American Bankers Association writes seeking guidance and relief from certain aspects of the Internal Revenue Service application process to obtain Employer Identification Numbers for trusts and estates of decedents.

  • Staff Analysis
    Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act)

    December 30, 2019

    ABA staff analysis and summary of key provisions on the SECURE Act.

  • Backgrounder
    How Does My Bank Trust Department Protect my Managed Assets?

    November 26, 2019

    Customers may wonder how their bank manages and holds the assets in their investment account. This backgrounder provides a brief explanation of how regulation, examination, and sound practices protect a bank customer's interests.

  • Comment Letter
    ABA Letter to SEC on Concept Release on Harmonization of Securities Offering Exemptions

    September 24, 2019

    As part of the effort to improve and harmonize the exemption framework, ABA urges the Commission to modernize through formal rulemaking the QIB definition as discussed in the letter.

ABA Speakers Bureau

A free member benefit, the ABA Speakers Bureau provides a diverse slate of expertise on important topics, and may be available to speak to your state association, leadership team, board of directors and more.