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How to Comment

Lucy Griffin, Editor, Compliance Action and BOL Guru

Sample Reg C Comment Letter
Specific Issues for Comment

BankersOnline is providing you with model comment letters and points you may want to consider and discuss in your own comment letter. Here are some tips to make your comment letter effective.

  1. For the commentor, the question is "can I do effectively and efficiently what the proposal would require?" Use some specific information which may include a description of your procedures, software, or training programs, to support or illustrate your point.

  2. There are lots of issues to cover. Select the issues that most concern you and comment on those issues with a fair amount of detail. These will have the most impact on the reader.

  3. Include numbers and practical examples of how the proposal would work. Regulators work in an ivory tower. The comment letter is your opportunity to give them a dose of reality.

  4. Include specific examples of how the proposal would require a process to change. Provide numbers on how many people would need new training, what that training would cost, how many forms would have to be redesigned, how many forms would be thrown away unused, how many people would be involved in the implementation process, what system changes would be required and how much time it would take to reconfigure the system.

  5. Send your letter. Every comment letter has an impact on the final rule. Get your letter in - vote early and often! But be sure to vote by the deadline the regulators have set.

Sample Reg C Comment Letter
Specific Issues for Comment

Copyright, 2001, BankersOnline. All rights reserved.

First published on 01/01/2001

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