Publications

Comment Letters

2013

April 2013

Joint Trades Letter Supportng CISPA
April 2013

BITS/Roundtable and 7 Financial Trades support H.R. 756, the "Cybersecurity Enhancement Act"; H.R. 967, the "Advancing America's Networking and Information Technology Research and Development Act"; and H.R. 1163, the "Federal Information Security Amendments Act"
April 2013

ITAC/BITS Comment Letter on SSA’s proposed policy on Assigning New Social Security Numbers for Children Age 13 and Under
April 2013

BITS/Roundtable and Joint Trade Associaions Support the Cyber Intelligence Sharing and Protection Act (CISPA)
April 2013

FSSCC - Developing a Framework to Improve Infrastructure Cybersecurity to The National Institute of Standards and Technology (NIST)
March 2013

BITS Social Media Guidance Comments to FFIEC
February 2013

Roundtable Supports Cyber Research and Development
February 2013

BITS/Roundtable Letter to House Permanent Select Committee on Intelligence on H.R. 624 Cyber Intelligence Sharing and Protection Act

2012

2011

November 2011

Roundtable Supports the Cyber Intelligence Sharing and Protection Act
November 2011

BITS Letter to the National Institute of Standards and Technology (NIST)
October 2011

Roundtable/BITS Letter to House Republican Cybersecurity Task Force
September 2011

Joint Trade Letter to CFPB on Disclosure of Records and Information
September 2011

Roundtable Letter to Federal Reserve on Interim Rule on Debit Card Fraud Prevention Adjustment
August 2011

Roundtable Letter to CFPB on Privacy Act Systems of Record
August 2011

BITS Letter to FTC on Dot Com Disclosures Business Guidance Publication
August 2011

Roundtable Statement of Support for the International Cybercrime Reporting and Cooperation Act
August 2011

BITS & ABA Letter to the Department of Health and Human Services on HIPPA Privacy Rule Accounting of Disclosures
June 2011

Roundtable Letter to CFTC on Swap Data Recordkeeping and Reporting Requirements
June 2011

Multi-Trade Letter to Federal Reserve on Regulation CC Revisions
May 2011

BITS Letter to ICANN Proposing Multi-Script Version Offerings
May 2011

Joint Trade Letter on Legal Entity Identifier Standardization Framework
April 2011

BITS Letter to FCC on Implementation of the Truth in Caller ID Act of 2009
March 2011

BITS Letter to NACHA on Security Framework
March 2011

BITS Letter to Agencies Regarding Authentication Guidance
January 2011

BITS Letter to DOJ on ADA Web Accessibility Guidelines
January 2011

BITS Letter to ICANN on Proposed Final New Applicant Guidebook Version 5

2010 and Prior

December 2010

BITS Letter to FinCEN on Cross-Border Electronic Transmittal of Funds
December 2010

BITS Letter to FinCEN on BSA-SAR Databases
November 2010

BITS Letter to ICANN on Proposed Final New Applicant Guidebook
November 2010

BITS Letter to ICANN on Potential Delegation of Financial Generic Top Level Domains
October 2010

BITS Letter to ICANN on High Security Zone Verification Program
September 2010

BITS Letter to the Department of Commerce on Cybersecurity
August 2010

Roundtable Joint Trades Letter to Senators Rockefeller and Pryor on S. 3742, Data Security and Breach Notification Act of 2010
July 2010

BITS Letter to ICANN on Top Level Domains Draft Applicant Guidebook Version 4
July 2010

BITS/Roundtable Letter to Chairman Frank on the Unlawful Internet Gambling Enforcement Act (UIGEA)
February 2010

BITS Letter to ICANN on Affirmation Reviews Proposal 3
February 2010

BITS/Roundtable Letter to State Department, FTC and Federal Reserve on OAS Model Law Proposal
December 2009

BITS/ITAC Letter to Social Security Administration on CBSV
November 2009

BITS Letter to ICANN on Top Level Domains Draft Applicant Guidebook Version 3
November 2009

BITS/Roundtable Letter to Treasury and Federal Reserve on Unlawful Internet Gambling Act
August 2009

BITS Letter to ICANN on Financial Generic Top Level Domains (gTLD)
July 2009

BITS Letter to Commerce Department on Asia Pacific Economic Cooperation (APEC) Data Privacy Pathfinder Pilot
July 2009

BITS Letter to OCC on Red Flags Programs Implementation Burden
June 2009

Roundtable/BITS Letter to Commerce Department on Assessment of the Transition of the Technical Coordination and Management of the Internet's Domain Name and Addressing System
May 2009

Roundtable/BITS Letter to SEC on Proposal for Model Privacy Form
April 2009

BITS Letter to ICANN on Draft Applicant Guidebook Version 2
December 2008

BITS Letter to ICANN on Draft Applicant Guidebook on Top Level Domains
October 2008

BITS/Roundtable Letter to Agencies on Risk-Based Capital Guidelines
May 2008

BITS/Roundtable Letter to Treasury et al. on Critical Infrastructure Partnerships/FSSCC Restructuring
May 2008

BITS/Roundtable Letter to SEC on Proposed Amendments to Regulation S-P
April 2008

BITS/Roundtable Letter to FTC on Online Behavioral Advertising Principles
December 2007

BITS/Roundtable Letter to Treasury and Federal Reserve on Prohibition on Funding of Unlawful Internet Gambling
October 2007

BITS/Roundtable Letter to ICANN on the WHOIS Database
September 2007

Roundtable/BITS/ITAC Letter to the Social Security Administration on CBSV Process
September 2007

Roundtable/BITS/ITAC Letter to FTC on SSNs in the Private Sector
May 2007

BITS/Roundtable Letter to Agencies on Interagency Proposal for Model Privacy Form
May 2007

BITS/Roundtable Letter to DHS on REAL ID Act
January 2007

BITS/Roundtable Letter to FTC on Federal Identity Theft Task Force Report
January 2007

BITS/Roundtable Letter to ICANN on Endorsement of Special Circumstances Model for WHOIS Database
September 2006

BITS/Roundtable Letter to Federal Banking Regulators on Proposed Identity Theft "Red Flags Rule"
August 2006

BITS/Roundtable Letter to Federal Banking Regulators on Meeting Basel II Capital Requirements
April 2006

BITS Letter to ICANN on the WHOIS Database
February 2006

BITS/Roundtable Letter to the Social Security Administration on Consent-Based Social Security Verification Process
February 2005

BITS/Roundtable Letter to FDIC Study on Putting an End to Account-Hijacking Identity Theft
November 2004

BITS/Roundtable Letter to Federal Reserve Board on Proposed Rule to Amend Regulation E
May 2004

BITS/Roundtable Letter to DHS on Procedures for Handling Critical Infrastructure Information
October 2003

BITS/Roundtable Letter to Agencies on Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice
December 2002

BITS/Roundtable Letter to Agencies on the Draft National Strategy to Secure Cyberspace
December 2002

Appendix to BITS Letter to Agencies on the Draft National Strategy
October 2002

BITS/Roundtable Letter to Agencies on the Draft Interagency White Paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System
October 2001

BITS Letter to W3C and P3P Working Group on the Platform for Privacy Preferences 1.0 (P3P 1.0) Specification, W3C Working Draft of September 24, 2001

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