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Page 4                                                               NDBA Legal Update • October 19, 2017


         fan.  In his view the proposal is “neither simpler nor less
         burdensome than the current rule.”  According to Hoenig,
         “It is just different.  It falls well short of achieving the kind of
         simplification that would provide truly meaningful benefit to
         the industry, investors, and the public.  Hoenig contends the
         proposal “will only perpetuate the disparate capital benefits
         across banks of different sizes and provide only minimal
         regulatory reporting relief. ABA has formed a working group
         to formulate comments on the proposal. If you are interested in
         participating, please contact Marilyn Foss about how to do so.


         How to Write an Effective
         Comment Letter


         One of the speakers at the Security Professional’s conference
         that was held in Bismarck last week urged attendees to be
         active in bank regulatory agencies’ rulemaking processes by
         submitting comment letters.  The speaker commented how
         letters by trade associations are helpful, but noted agencies
         are very much interested in hearing from the banks which are
         directly affected by rules and changes to rules.  NDBA agrees:
         banker comments are at least as effective as those by trade
         associations and often carry more impact.
         ABA has prepared materials to help bankers write effective
         comment letters.  The points apply whether a letter is
         responsive to a federal or state agency proposal.  Here’s the link:
         https://www.aba.com/Compliance/Pages/Comply_EffectiveCL.
         aspx?utm_campaign=COMPLIANCE-20171002&utm_
         medium=email&utm_source=Eloqua.






















                                Role of the General Counsel
                                North Dakota Bankers Association is extremely fortunate to have the expertise of Marilyn Foss on staff.
                                Marilyn has been with the association for over 19 years as general counsel and has served our members
                                and staff with great professionalism.
                                NDBA’s general counsel serves as the attorney for the association. Although she is pleased to be able to
                                serve as a resource for NDBA members in responding to their questions, she is providing general information,
                                not legal advice. Banks must obtain legal advice from counsel who has been retained by the bank to
                                represent the bank’s interests in a specific matter.
          Marilyn Foss
          NDBA General Counsel  To contact Marilyn Foss, NDBA General Counsel, call 701.223.5303 or email at marilyn@ndba.com.
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