NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)

[Gunnar Larson]

For some reason, when 'I want my first checks in Bitcoin' is running around
town.

Gunnar

On Thu, Jul 27, 2023, 7:38 AM Gunnar Larson <g at xny.io> wrote:

> I want my first checks in Bitcoin.
>
> On Wed, Jun 28, 2023, 2:14 AM Gunnar Larson <g at xny.io> wrote:
>
>> Ms. Scott:
>>
>> Additionally, xNY.io - Bank.org respectfully submits Coinbase's Brian
>> Armstrong on Bloomberg.com:
>> https://www.bloomberg.com/news/videos/2023-01-12/the-david-rubenstein-show-coinbase-s-brian-armstrong as
>> a matter for public  comment for NY-DFS' "Proposed Guidance on Character
>> and Fitness."
>>
>> The Bloomberg interview with Coinbase showed top journalistic integrity,
>> yet, Coinbase failed to mention any NY-DFS investigation or pending action.
>> The interview aired last December, before the 100M Coinbase settlement was
>> announced by NY-DFS concerning Coinbase's BitLicense compliance.
>>
>> NY-DFS' approach to Coinbase and Goldman Sachs (who took Coinbase public)
>> share independent insider trading scenarios that could disrespect the
>> United States Department of Justice, Criminal Division, Fraud Section and
>> Money Laundering and Asset Recovery Section compliance programs.
>>
>> We have collated 34 highlights that describe a corporate opportunity
>> policy framework to gauge character and fitness of the "first Bitcoin loan"
>> backed by a New York banking institution here:
>> https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=drivesdk
>> .
>>
>> Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and
>> Ongoing Assessment of Designated Persons’ Character and Fitness," can you
>> kindly acknowledge that you have reviewed and understand our appeal seeking
>> extension for public comment to August 5, 2023?
>>
>> We feel extra time for public comment is warranted to ensure that xNY.io
>> - Bank.org did not play a significant role or otherwise contribute in a
>> meaningful way to the conduct that led to regulatory action or proceeding
>> without ample notice.
>>
>> Thank you,
>>
>> Gunnar
>>
>> On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g at xny.io> wrote:
>>
>>> Ms. Scott:
>>>
>>> NY-DFS recently asked for public comment concerning "Proposed Guidance
>>> on Assessment of the Character and Fitness of Directors, Senior Officers,
>>> and Managers" mentioned here:
>>> https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidance_assessment_fitness
>>> .
>>>
>>> xNY.io - Bank.org asks if the NY-DFS will extend deadline for public
>>> comment to August 5, 2023 from June 30, 2023.
>>>
>>> As requested by NY-DFS, today we provide (in a separate attachment)
>>> evidence of any documented exceptions to compliance with the "Suggested
>>> Questions to Facilitate Initial and Ongoing Assessment of Designated
>>> Persons’ Character and Fitness."
>>>
>>> We have collated 19 references comprising 205 highlights that touch on
>>> the five key areas below:
>>> https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO
>>> .
>>>
>>> -Harassment and Discrimination Policies
>>>
>>> -Conflict of Interest Policy
>>>
>>> -Insider Trading Policy
>>>
>>> -Records Management Policy
>>>
>>> -Corporate Opportunity Policy
>>>
>>> xNY.io - Bank.org is seeking NY-DFS' extension for public comment to
>>> August 5, 2023 so that the New York Banking community has time to complete
>>> Q2-23 earnings call disclosures.
>>>
>>> As documented in the above 19 references, we feel extra time for public
>>> comment is warranted to ensure that xNY.io - Bank.org did not play a
>>> significant role or otherwise contribute in a meaningful way to the conduct
>>> that led to regulatory action or proceeding without ample notice.
>>>
>>> Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and
>>> Ongoing Assessment of Designated Persons’ Character and Fitness," can you
>>> kindly acknowledge that you have reviewed and understand our appeal seeking
>>> extension for public comment to August 5, 2023?
>>>
>>> We hope to hear from you before June 30, 2023 given obvious factors.
>>>
>>> Sending you the very best regards.
>>>
>>> Thank you,
>>>
>>> Gunnar
>>>
>>> --
>>> Gunnar Larson
>>> xNY.io | Bank.org
>>> MSc - Digital Currency
>>> MBA - Entrepreneurship and Innovation (ip)
>>>
>>> G at xNY.io
>>> +1-917-580-8053
>>> New York, New York 10001
>>>
>>>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: not available
Type: text/html
Size: 7167 bytes
Desc: not available
URL: <https://lists.cpunks.org/pipermail/cypherpunks/attachments/20230727/71d5fa08/attachment.txt>