Anonymous 34

I write in strong opposition to this proposed rule due to the exemption from FDIC insurance, a lack of transparency, apparent conflicts of interest, and questions about foreign ownership, as outlined below. 1. Lack of FDIC insurance. Deposit insurance through the Federal Deposit Insurance Corporation is the national standard for any bank chartered in the United States as it provides security for depositors up to $250,000. The proposal offers no coherent rationale for why it should be exempted from FDIC insurance; for this reason alone it should be rejected. 2. Lack of transparency. Of two supporting documents - Confidential Business Plans (CBP) A and B - only the basic organizational chart in CBP A is viewable. While some elements of this proposal must understandably remain confidential, CBP B is sealed from public view. This prevents the public from viewing the ownership structure, any capital arrangements or even a summary thereof, distribution of revenues and interest on reserves, or business arrangements (contracts or otherwise) with outside companies/vendors. Without this transparency, this proposed rule does not take reasonable measures to ensure that this bank will be a vehicle for money laundering and/or the financing of terrorism. 3. Appearance of conflict of interest. Several members of the proposed management team and Board are principals, employees, relatives, or advisors to members of the current Administration or businesses owned by members of the Administration. This places them in the appearance of direct conflict of interest with the proposed rule; beneficiaries of this bank would effectively also be regulating it. Furthermore, the current Comptroller of the Currency was appointed by the current President and would also decide whether or not to apply oversight of the bank. This calls into question the impartiality of the proposed bank's regulator, the Office of the Comptroller of the Currency (OCC): according to a recent US Supreme Court decision, heads of independent agencies effectively serve at the pleasure of the President; given the current President's family financial stake in the bank, the OCC would appear to be beholden to the President's personal financial interests regarding oversight and possible enforcement should irregularities arise. Without resolution of this apparent conflicts of interest, this proposed rule should be rejected. 4. Questions of foreign influence. In testimony before the Senate banking Committee earlier this year, the Comptroller of the Currency was unable or unwilling to fully answer questions regarding the existing minority ownership (49%) by a firm with direct ties to the government of the United Arab Emirates of the parent company of the proposed bank. Foreign influence over any United States bank would be of concern in any case; given the mitigating factors listed in items 1, 2, and 3 above, this major stake owned by a foreign company under the influence of a foreign government is a red flag of the highest degree. For the reasons above, I oppose the proposed rule and hope to see it rejected for the good of our great nation. Thank you for the opportunity to comment.