[DeadMoneyDad]

[ QUOTE ]


Why aren't they pitching yet another one of their patented fits? Am I missing something? I just went to FOF and NCALG websites and still don't see anything about it.

Sometimes quiet where noise should be means something big and bad. I know I have kids.

[/ QUOTE ]

IMO either they feel as I do that the issue is in the hands of the banks. The Fed Reserve and the Treasury gave the banks many different ways to implement these regulations, from creating a black-list all the way to the use of the OFAC list.

The result is the same since we chose not to try and fight the banks by showing our displeasure in any of a number of different ways. As long as the banks are happy and don't oppose the regs then no one else has to try and pressure the banks to implement them. Why waste the effort in a fight already decided, the KY argument.

As to the quietness issue it could also be as I said the way proposed reg fights are often fought. You wait until the end to see where you want to position yourself for the "re-drafting" if needed. You read all the initial submissions and attempt to defeat any comments that you feel nessecary. Then you lobby the Agencies involved once you have a full picture of the comments and Agency views. If nessecary you go to the Hill and presure the Agencies funding and oversight committees.

Dec 12 was just the first date in this issue. The PPA chose not to put any presure on the banks in any visible way to try and change their initial acceptance of the proposed regualtions. So we write letters and hope to get a fair hearing of the issues based on reason and logic.

Sorry but IMO that just isn't the way this game is played nor won.


D$D