I'm denying the existence of W until it gets published in the Federal Register. There's something about printing the double-spaced, wide-margin version published by the Fed that is unsettling. "W" is as long as the Privacy proposal, and Privace was inter-agency.
The Federal Register .pdf version, even though it will be the same, will be 1/4 of the size of Board of Gevernor's printeed version. Psychologically, that will be much easier to digest.
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Opinions expressed are not necessarily those of my employer.
Paul Brinker CRCM
Director, Corporate Compliance
First National Bank of Omaha
402-964-8313