Phoebe Papageorgiou

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.

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.

July 05, 2022

ABA urges the SEC to clarify that Rule 17Ad-16 only requires a Notice with the DTCC in specific circumstances.

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.

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.

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.

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.

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.

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.

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.

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.'

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).

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.

May 04, 2020

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

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.

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.

December 30, 2019

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

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.

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.

August 02, 2019

ABA comment letter regarding the Delaware Proposed Amendment to Trust Company Charter Applications.