10-01-15 Proposing a simple review standard to US Office of Comptroller of the Currency.

  

Date: Fri, 15 Jan 2010 20:05:46 -0800
To: "US Office of Comptroller of Currency"
From: joseph zernik
Subject: RE: Case #00971981 - Complaint against Bank of America Corporation, for conduct that was alleged as amounting to racketeering in the courts in Los Angeles County, California - review procedures.

Office of the Comptroller of the Currency

RE: Case #00971981 - complaint against Bank of America Corporation, for conduct that was alleged as amounting to racketeering in the courts in Los Angeles County, California - review procedures.

Dear Office of Comptroller of the Currency:

In a phone call today with Sonya, a phone representative at OCC, I was glad to hear that after two "escalations" Bank of America finally filed two letters with OCC, dated January 8, 2010, as a response to the complaint referenced above, dated September 29, 2010.  However, I was also informed, that following OCC's standard procedures, while the bank was allowed to view my complaint, I would not be allowed to view the response.

I therefore filed today a Freedom of Information Act request for the records.  Regardless, based on past experience, it was unlikely that I would get any of the records prior to OCC's determination in this matter.

Past experience in the same and related matters included, but was not limited to:

a) A complaint to Office of Thrift Supervision CASE #0507312007 against Countrywide Bank, in 2007, on the same matter.
Thrift Supervision practiced the same review standards as described above.  When I later obtained records through a Freedom of Information Act request, it became apparent that Countrywide provided Office of Thrift Supervision false and deliberately misleading responses, unsubstantiated, and inherently illogical.  Regardless, such responses were accepted and quoted verbatim as the determination by that office.

b) A complaint to OCC, # 00974775 against Union Bank, filed in 2009, currently under appeal, on a related matter.
Union Bank's has refused in the past 2.5 years  to allow me any any access to my own banking records in this matter.  The  response to OCC was likewise - a narrative with no documentary substantiation at all. Such response was nevertheless accepted by OCC, and the complaint was closed.

Therefore, since I would be able neither to see Bank of America's response on my complaint, nor to reply prior to OCC's determination,  I am writing to propose a review standard that I suggest would amount to fundamental integrity in banking regulation:

In my complaint I provided links to records to substantiate each and every one of my claims.   I request that OCC would not accept any response from Bank of America on my complaint, unless it provided documentation to substantiate the narrative of the response. 

I hope that you share my concerns regarding integrity of banking regulation under the current crisis, and would therefore accept this simple suggestion.

Truly,

Joseph Zernik
http://inproperinla.blogspot.com/
http://www.scribd.com/Free_the_Rampart_FIPs
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CC:
1) Kevin Bailey - Deputy Comptroller
2) Basel Accords Committee
3) Mary Schapiro - SEC
4) David Kotz - SEC-IG
5) Eric Thorson - Treasury-IG