[Johnny McEldoo]

TE,

I like the letter. At the same time, I wonder if it would be better to attack section by section instead of a general letter format. Also show support for things we like.

For example in the section about exemptions they say:
"The Agencies request comments on all aspects of the exemptions, but in particular, whether the exemptions for certain participants in the ACH systems....are appropriate"

Shouldn't we take the time to echo our support for the ability for financial institutions to receive exemptions and state that we expect that these exemptions will be granted to such financial entities requesting them.

I would think this is important to fight off the FOF type groups when they fight against specific sections and we are silent.

How easily one of these financial institutions are granted an exemption seems like a big thing...