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> (email exchange)
> On Wed, Aug 19, 2009 at 11:58 PM, Roger wrote:
> this is fascinating – any sense whether the implementers were aware of the disparate
> consequences of this approach, as opposed to completely unaware of the
> consequences for different size banks?
They are aware but it might not be their job to care about the consequences.
> I have copied two links, the first is the letter from the director of the ABA discussing
> the issue. Inside that letter is another link (the second one I have below) which is
> the instructions for the Call Report. These issues are not regulations, but inter-agency
> directions for reporting in the Call Report. If you want anything else, let us know.