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ABA Comment Letters
2009
- ABA Comment Letter on Derivatives and Hedging (Topic 815) - Scope Exception Related to Embedded Credit Derivatives November 12, 2009
- ABA Comment Letter on Reg Z Impact November 4, 2009
- ABA Comment Letter on Proposed Rulemaking on Board of Directors of the FHLB System Office of Finance 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
- No.1710-100 Fair Value Measurements and Disclosures (Topic 820) - Improving Disclosures about Fair Value Measurements October 6, 2009
- CDFI NMTC Application October 2, 2009
- Regulatory Capital Limits on Deferred Tax Assets September 25, 2009
- DTA Historical Perspective Total September 2009
- ABA Comment Letter to FHFA - ANPR- Duty to Serve Underserved Markets for Fannie Mae and Freddie Mac 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 Comment on Consolidation of Asset-Backed Commercial Paper Programs and Other Related Issues, 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 Comment on Guidelines for Furnishers of Information to Consumer Reporting Agencies, August 28, 2009
- ABA on FinCEN Proposal re: Possible AML Program for Non-bank Mortgage Lenders, August 20, 2009
- ABA Comment Letter on Proxy Access Proposal August 17, 2009
- ABA Comment Letter to Treasury 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
- SEC Custody Proposal, July 28, 2009
- Mortgage Assistance Relief Services, July 15, 2009
- ABA Comment on Residential Mortgage Loans Modified Pursuant to the Making Home Affordable Program, July 13, 2009
- NACHA Proposal re: Direct Access Registration, July 10, 2009
- Interagency SAFE Act Rules that would Require Loan Originators Employed and Supervised by Depository Institutions to Register with a 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
- ABA Comment on Regulatory Capital Adjustments Required in Response to FASB Sales and Consolidation Accounting Changes 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
- Changes to Reg Z, June 4, 2009
- NACHA Customer Service Telephone Number RTI May 28, 2009
- ABA and CBA Comment on Regulation Z, HEOA, May 26, 2009
- Federal Housing Finance Agency (FHFA) on the interim final rule on Capital Classifications and Critical Capital Levels for the Federal Home Loan Banks, May 18, 2009
- International Banking Federation Comment on IADI and Basel Committee Consultative Document on Core Principles for Deposit Guarantee Schemes, May 15, 2009
- FinCEN 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 for Brokered Deposit Interest Rate Restrictions for Banks that are Not "Well Capitalized," April 6, 2009
- National Credit Union Administration Comment Letter, April 3, 2009
- Porting under TCPA, 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
- 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, Jan. 9, 2009
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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
- FDIC Assessments 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
- 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 Proposal, 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
- FDIC re: CDARS , July 29, 2008
- ABA Raises Implementation Concerns with the IRS' Automatic Contribution Arrangements Proposal, July 25, 2008
- FDIC's Financial Education Programs, July 23, 2008
- FDIC National Unbanked and Underbanked Household Survey, July 18, 2008
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- 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
- ABA-FSR-TCH letter on FDIC Proposal for Processing of Deposit Accounts in a Bank Failure and Large-Bank Deposit Insurance Determination Modernization, April 16, 2008
- FDIC on Processing of Deposit Accounts in a Bank Failure and Large-Bank Deposit Insurance Determination Modernization, April 14, 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
- ABA and The Clearing House Comment on Proposed Reporting Requirements for Basel II Advanced Approaches Banks, February 25, 2008
- Letter to the Committee of European Banking Supervisors on its 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
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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, 2007
- Elimination of IFRS to GAAP Reconciliation, September 21, 2007
- Proposed DIG E23, September 21, 2007
- FSP FAS 140-d, September 21, 2007
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2006
- Letter to IRS Proposed Regulation Regarding Section 1221(a)(4) 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
- FDIC 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 and Mutual Holding Company Structures 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
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2005
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2004
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2003
- Conversion of Credit Unions to Mutual Savings Banks December 1, 2003
- Risk-base d capital treatment of asset-backed commercial paper programs November 17, 2003
- Internal Ratings-Based Systems for Corporate Credit and Operational Risk November 3, 2003
- Federal Government Participation in ACH October 21, 2003
- Response Programs for Unauthorized Access to Customer Information and Customer Notice October 14, 2003
- OCC Preemption October 6, 2003
- EGRPRA Reg Burden Review September 15, 2003
- Revised definition of credit union organization September 2, 2003
- Deposit insurance coverage of living trust accounts August 29, 2003
- FinCen's Strategic Plan August 22, 2003
- Notice of Inquiry July 31, 2003
- Delay in Certain Regulations on DCCs and DSAs on 3rd-Party, Closed-End Loans - July 14, 2003
- Member Business Loans June 3, 2003
- Proposed HMDA (Reg. C) Transition rules April 8, 2003
- OCC Visitorial Proposal April 8, 2003
- Economic Sanctions Enforcement Guidelines March 31, 2003
- Preemption of Georgia Law March 28, 2003
- Proposed TFR Changes for 2004 March 24, 2003
- FHA regulations March 14, 2003
- Public Welfare Investment Authority March 11, 2003
- US Postal Service Issues February 5, 2003
- Organization and Operations of Federal Credit Unions January 31, 2003
- Proposed Abbreviated Net Worth Restoration Plan January 28, 2003
- Sec. 311 - Designation of Jurisdictions January 27, 2003
- Proposed changes to the Regulation Z Commentary January 27, 2003
- Patriot Act Task Force January 23, 2003
- Proposed Revisions to the 2003 Call Reports January 7, 2003
- Revised SAR Financial Institutions January 3, 2003
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2002
- Major modification to RESPA, October 28, 2002
- Proposed Guidance on Credit Card Lending, September 23, 2002
- Proposed Revisions to the Call Report and New Subprime Lending Reporting Items, September 10, 2002
- Implementation of Section 326 of the USA Patriot Act (Customer Information Program) September 6, 2002
- Proposed Changes to Discount Window Operations August 22, 2002
- Review of Real Property Appraiser Qualification Criteria August 15, 2002
- Proposed changes from the OFAC to the rules governing availability of certain civil penalty information under 31 CFR 501.805 July 19, 2002
- HUD-Notice of Proposed Information Collection: Comment Request; Real Estate Settlement Procedures Act (RESPA) Disclosures April 29, 2002
- DHHS - Standards for Privacy of Individually Identifiable Health Information; proposed rule modification April 26, 2002
- FRB - Proposed supplemental HMDA changes (Reg C) April 12, 2002
- FTC - Telemarketing Rulemaking April 10, 2002
- FDIC - Policy Statement Regarding Minority-Owned Depository Institutions March 4, 2002
- NCUA - Organization and Operation of Federal Credit Unions February 15, 2002
- Treasury - Money Laundering Requirements for Correspondent Accounts February 11, 2002
- FRB - Regulation Z February 1, 2002
- HUD - FHA Appraiser Roster Licensing January 29, 2002
- NCUA - Investment and Deposit Activities January 24, 2002
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2001
- OCC - Proposed Assessment Increase for 2002 October 25, 2001
- OCC, FDIC, FRB, OTS - Advance Notice of Proposed Rulemaking on the Community Reinvestment Act Regulations October 17, 2001
- FRB, OTS, FDIC - Study of Banking Regulations Regarding the Online Delivery of Financial Services August 20, 2001
- FDIC - "Engaged in the Business of Receiving Deposits Other Than Trust Funds" July 18, 2001
- OCC - Proposed Consumer Protections for Debt Cancellation Contracts June 18, 2001
- FDIC, FRB, OCC - Admendment to Rule Prohibiting Use of Interstate Branches for Deposit Production June 6, 2001
- Basel Committee Proposal to revise the Risk-Based Capital Standards May 31, 2001
- NCUA - Credit Union Service Organizations April 23, 2001
- FRB - Regulation Z - Proposed Changes to High Cost Mortgage Rules March 9, 2001
- FRB - Proposed HMDA-Regulation C Amendments March 9, 2001
- NCUA - Federal Credit Union Incidental Powers February 22, 2001
- NCUA - Corporate Credit Unions; Advance Notice of Proposed Rulemaking February 20, 2001
- OTS - Saving and Loan Holding Companies; Notice of Significant Transactions or Activities and OTS Review of Capital Adequacy February 9, 2001
- FDIC, FRB, OCC, OTS - ANPR for Simplified Capital Framework for Noncomplex Banks February 1, 2001
- AOUSC - Privacy and Public Access to Electronic Case Files January 25, 2001
- Request for Comment on ABA Corporate Trust Risk Management Outline January 8, 2001
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2000
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