2008 Comment Letters (Federal)

Regulation Z

 

2008 Comment Letters (New York State)

Power of Attorney

ATM Transaction Denial Fees

Check Cashing

Credit Unions and the Linked Deposit Program
 

High Cost Home Lending


2008 Testimony (New York State)

Statement on Executive Budget 2008-2009
                   
                 
2007 Comment Letters (New York State)


Bank and REIT Taxes

Universal Default
Governor's Spitzer's VETO Message: Universal Default

IOLA

ATM Surcharges on Foreign Bank Accounts

Adverse Credit Actions Due to Identity Theft

Wild Card

Credit Score Determination

Linked Deposit Programs

Credit Card Transaction Forms

Short Form Power of Attorney
Governor Spitzer's VETO Message: Short Form Power of Attorney

Use of Social Security Numbers
Governor Spitzer's VETO Message: Use of Social Security Numbers

Definition of Industrial Bank


2007 Memoranda in Opposition

Universal Default, June 29, 2007

Late Fees, May 22, 2007

Credit Scores, February 13, 2007

Late Fees, February 13, 2007

ATM Fees, February 5, 2007

DTF Bank Tax Report
 

2007 Testimony

NYBA's Testimony regarding the 2009 Executive Budget

NYBA's Testimony before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, and Oversight, Analysis and Investigation on subprime lending practices.

Testimony by John Bryant, President of Operation Hope before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, and Oversight, Analysis and Investigation on subprime lending practices.

NYBA's Testimony before the NYS Senate Standing Committee on Consumer Protection, the NYS Assembly Standing Committee on Consumer Affairs and Protection, and the NYS Assembly Committee on Banks on the practices of credit card companies.

NYBA's Testimony before the NYS Senate Finance Committee and the NYS Assembly Ways and Means Committee on the proposed Bank Tax increases.

2007 Comment Letters (Federal)

NYBA's comments on garnishment of exempt federal benefits

NYBA's comments to the Office of Thrift Supervision on Unfair or Deceptive Practices (UDAP)

NYBA's comments on IRS proposed rulemaking on Section 67 Limitations on Trusts and Estates

NYBA's letter to Senators Schumer and Clinton opposing the Chambliss Amendment to the Farm Credit Bill

2006 Testimony

NYBA's Statement at the NYS Assembly Banks and Consumers Affairs Committees Hearing on Financial Services for Low-Income Consumers

NYBA's Statement at the NYS Assembly Banks Committee Hearing on Banks' Discontinuance of Money Service Business Accounts
 

2006 Comment Letters

FDIC Proposal regarding risk differentiation frameworks and the base assessment rate schedule.

OTS Proposal regarding stock benefit plans in mutual-to-stock conversions and mutual holding company structures.

2006 New York State Legislative Comment Letters to Governor Pataki
Including: compensating use taxes paid on certain credit card accounts; examination intervals; credit line mortgages; information subpoenas; certain trust acquisitions; executive officers of savings banks; licensing of check cashers; and ATM lighting

FASB EITF Issue 06-4 "Accounting for Deferred Compensation and Postretirement Benefit Aspects of Endorsement Split-Dollar Life Insurance Arrangements"

FASB Proposal on Employers' Accounting for Defined Benefit and Other Plans

Federal Regulators' Proposed Guidance on Concentrations in Commercial Real Estate
 

New York Attorney General's Proposed Rulemaking on Registration of Charitable Entities

Amendments to the Deposit Insurance Assessment System

2005 Testimony

Banking Development Districts

Consumer Privacy

Privacy/Identity Theft (New York City)

Privacy/Identity Theft (New York State)

Privacy/Use of Social Security Numbers (New York State)

Overdraft Fees and Bounce Protection Programs (New York State Banking Dept.)

2005 Comment Letters

FDIC re Wal-Mart Bank Deposit Insurance Application

Privacy/Identity Theft

FHLB Letters of Credit

Transfer on Death Security Registration