September 28, 2001

Mr. T. Whittier Warthin
Director, Financial Services Negotiations
U.S. Treasury Department
1500 Pennsylvania Avenue, N.W.
Washington, D.C. 20220

Dear Whit:

On behalf of the Conference of State Bank Supervisors (“CSBS”) I am submitting this letter in response to your letter soliciting comments from state regulators concerning the financial services aspects of the free trade agreements (“FTAs”) currently under negotiation. Specifically, I am writing on behalf of Mr. Michael Lesser of the New York State Banking Department and Ms. Linda Townsend of the Florida Division of Banking, Chair and Vice Chair, respectively, of the CSBS International Regulatory Task Force.

As you know, CSBS is the professional association of state government agencies that charter, regulate and supervise the nation’s 6,085 state-chartered domestic banks and the 560 state-licensed branches and agencies of foreign banks. These 560 state-licensed branches and agencies of foreign banks account for approximately 87 percent of the $1.3 trillion assets of foreign banks doing business in the United States.

First and foremost, I would like to express our appreciation for discussing with us the financial services aspects of the FTAs and taking into account the experience, knowledge base, and expertise of the state banking system in your deliberations and negotiations. We believe it has been a most productive experience, and look forward to continuing our excellent working relationship.

We have shared your letter with the banking regulators of the 50 states, the District of Columbia and Puerto Rico, and advised them to contact you directly with comments any of them may have. We respectfully request that you carefully consider any comments you receive, and we stand ready to work with you to address those comments as appropriate. At this point in the negotiations, the CSBS International Regulatory Task Force has only one request. We respectfully request that date from which state measures (i.e., laws, etc.) are “grandfathered” be prospective, preferably the date on which the legislation implementing the FTAs is enacted. If you need our assistance in securing such an effective date, please do not hesitate to contact us.

Thank you for your careful consideration of the comments of state bank supervisors and the views of CSBS the International Regulatory Task Force. We look forward to working closely with you as the negotiations proceed.

Sincerely,



Timothy N. Bergan
Senior Vice President, International
Conference of State Bank Supervisors
1015-18th Street, N.W.
Suite 1100
Washington, D.C. 20036

Telephone: 202-728-5725

cc: Ms. Mary Beasley