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Comment Letters
2008
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2008 Comment Letters

Letter to FASB on proposed FASB Staff Position EITF 99-20-a
12/30/08
Letter to Fed on Proposed Revisions to Form FR Y 9C
12/23/08
Letter to FDIC on Risk-Based Assessment System and Revision of Deposit Insurance Assessment Rates
12/17/08
Letter to NCCUSL on Payments Law Reform
12/17/08
Letter to OCC, Fed, and FDIC on revisions to Call Reports
11/24/08
Letter to FASB on Accounting for Transfers of Financial Assets-an Amendment of FASB Statement No. 140
11/13/08
Letter to FASB on Proposed Statement of Financial Accounting Standards - Amendments to FASB Statement No. 46(R)
11/13/08
Letter to OFAC on its interim Economic Sanctions Enforcement Guidelines
11/7/08
Letter to Treasury Department and IRS requesting clarification on Notice 2008 83 which provides guidance for the proper treatment of certain items of deductions or loss allowed after an ownership change to a corporation
10/31/08
Letter to FDIC on recordkeeping requirements for qualified financial contracts
10/30/08
Letter to OCC, Fed, FDIC, and OTS on the Deduction from Tier 1 Capital of Goodwill Net of Associated Deferred Tax Liability
10/28/08
Letter to IRS on Settlement Guidelines for Certain Structured Finance Transactions Referred to as "Foreign Tax Credit Generators"
10/24/08
Letter to FDIC Requesting an Extension of Time to Respond to the Proposal Regarding Recordkeeping Requirements for Qualified Financial Contracts
9/23/08
Joint letter to Basel Committee on Banking Supervision from Wolfsberg Group Co-chairmen and TCH commenting on its consultative document "Due Diligence and Transparency Regarding Cover Payment Messages Related to Cross-Border Wire Transfers"
9/12/08
Letter to Center for Audit Quality responding to draft white paper "Application of Statement 114 to Residential Mortgage Loans Subject to Modification"
9/5/08
Letter to Financial Accounting Foundation on FASB?s Accounting Standards Codification Project
9/5/08
Letter to Treasury Department on possible regulations on interest expense disallowance rules under IR Code section 265(b)
8/20/08
Letter to IRS requesting an extension of time to respond to the invitation to participate in the LILO/SILO settlement initiative
8/13/08
Letter to FASB on proposed amendment to FAS 5 and 141(R) on Disclosure of Certain Loss Contingencies
8/7/08
Letter to Basel Committee on Banking Supervision commenting on Principles for Sound Liquidity Risk Management and Supervision
7/31/08
Joint letter to Senate Finance and House Ways and Means Committee in support of delaying the effective dates for new merchant payment card information reporting
7/15/08
Joint letter with ABA, ETA, and FSRound Table in support of the Crapo amendment to delay the effective dates for new merchant payment card information reporting
7/7/08
Letter to OFAC regarding guidance on entities owned by blocked persons
7/2/08
Letter to Fed requesting clarification of amendments to Regulation D regarding time deposit open accounts
6/24/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to Senate Finance Committee opposing the use of payment card reporting proposal as a revenue offset for any legislation
6/19/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to House Ways and Means Committee opposing the use of the payment card reporting proposal as a revenue offset for any legislation
6/18/08
Joint letter with the ABA and ABASA to FINRA on its proposal for supervision of persons who are dual employees of banks and broker dealers
6/13/08
Joint letter with ABA, ETA, FSRound, NAM, NRA, and U.S. Chamber of Commerce to House Small Business Committee opposing information reporting on payment card reimbursements to merchants
6/12/08
Letter to Fed on payment system risk policies and daylight overdraft posting rules
6/11/08
Joint letter with Council on State Taxation and numerous other organizations opposing the NCCUSL project to revise the Uniform Division of Income for Tax Purposes Act
5/28/08
Letter to Senate Finance Committee on information reporting on electronic payment mechanism reimbursements
4/30/08
Letter to IRS endorsing SIFMA's letter on mark to market tax accounting rules
4/23/08
Joint letter with ABA and FSR on proposed rules regarding processing of deposit accounts in a large bank failure
4/16/08
Joint letter with ABA, ETA, FSR, NAM, and US Chamber of Commerce opposing proposed legislation to require information reporting on payment card reimbursements and using it as a revenue offset for the Farm, Nutrition and Bio-energy Act (H.R. 2419)
4/16/08
Letter to FDIC on proposed rules regarding the processing of deposit accounts in a large bank failure
4/15/08
Letter to IRS on proposed guidance for tax information reporting for mortgage insurance premiums
3/27/08
Joint letter with ABA to OCC, Fed, FDIC, and OTS on regulatory reporting requirements relating to Basel II
2/25/08