ABA Comment Letters
2012 Dodd-Frank Act developments are tagged
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- ABASA Comment Letter regarding 'Enhanced Prudential Standards', April 30, 2012
- ABA Recommends Changes to FATCA Proposal, April 30, 2012
ABASA Comment on Enhanced Prudential Standards, April 30, 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
- 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
- IBFed response to Basel Committee Proposal on the Definition of Capital, March 6, 2012
Comment on Assessment of Fees on Large Bank Holding Companies and Nonbank Financial Companies Supervised by the Federal Reserve Board, March 5, 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
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
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
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Letter regarding disposition of REO properties held by Fannie, Freddie and FHA, September 15, 2011
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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
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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 5, 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
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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
- 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
- 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
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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
- 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
- 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
- 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
- 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
Questions? For more information, contact webmaster@aba.com.

