State regulators are charged with protecting consumers and ensuring the safety and soundness of the financial institutions they supervise.

The Honorable Pat Toomey Ranking Member Senate Banking Committee Washington, D.C. 20510 Dear Ranking Member Toomey, The Conference of State Bank Supervisors (CSBS) 1 appreciates the opportunity to highlight the critical role of state bank regulators in supervising money transmission and virtual currencies. State regulators charter and supervise 79 percent of all U.S. banks and are the primary regulators of

Financial Crimes Enforcement Network Enforcement and Compliance Division P.O. Box 39 Vienna, VA 22183 FINCEN-2022-0007 RIN 1506-AB55 Re: Advance Notice of Proposed Rulemaking – No-Action Letter Process Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”)1 appreciates the opportunity to provide input on the Advance Notice of Proposed Rulemaking (“ANPR”) issued by the Financial Crimes Enforcement Network (“FinCEN”)

Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. OP-1747 Re: Supplemental Notice - Proposed Guidelines for Evaluating Account and Services Requests Dear Ms. Misback, The Conference of State Bank Supervisors (“CSBS” or “state bank regulators”) appreciates the opportunity to comment on the Supplemental Notice of

Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. OP‐1788 Re: Guidelines for Evaluating Account and Services Requests Dear Ms. Misback: The Conference of State Bank Supervisors (“CSBS”) appreciates the opportunity to comment on the proposed amendments to the Federal Reserve Board’s (“Board”) Guidelines for Evaluating

Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. OP-1747 Re: Proposed Guidelines for Evaluating Account and Services Requests Dear Ms. Misback, The Conference of State Bank Supervisors (“CSBS”) appreciates the opportunity to comment on the Proposed Guidelines for Evaluating Account and Services Requests (the “proposed

In this letter, CSBS raises concerns regarding the impetus for and permissibility of these contemplated proposals and reiterates concerns regarding the validity of the OCC’s multistate fiduciary operations rules.

CSBS comments on the FDIC's proposed rulemaking in regard to permissible interest races on transferred loans.

In a comment letter to House Committee on Financial Services Chairwoman Maxine Waters, CSBS supported and offered suggestions to a draft amendment to the Bank Secrecy Act.

State regulators believe this framework has been effective in protecting consumers. The proposed amendments to the Safeguards Rule would bolster the consumer protections ensured by the rule and would not prevent states from imposing stricter requirements.