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

[Gunnar Larson]

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
>>
>>
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