Public Comment AC96 Risk Based Capital Guidelines State Street Corporation, Boston, MA

Stefan M. Gavell Executive Vice President and Head of Regulatory and Industry Affairs State Street Corporation 1 Lincoln Street P.O. Box 5225 Boston, MA 02206-5225 Telephone: 617-664-8673 Facsimile: 617-664-4270 smgavell@statestreet.com March 26, 2007 Office of the Comptroller of the Currency Jennifer J. Johnson, Secretary 250 E Street, SW., Mail Stop 1-5, Board of Governors of the Washington, DC 20219 Federal Reserve System Docket Number 06-15 20th Street and Constitution Avenue, NW Docket Number 06-09 Washington, DC 20551 regs.comments@occ.treas.gov Docket Number No. R-1238 -1261 regs.comments@federalreserve.gov Robert E. Feldman Regulation Comments Executive Secretary Chief Counsel’s Office Attn: Comments/Legal ESS Office of Thrift Supervision Federal Deposit Insurance Corporation 1700 G Street, NW 550 17th Street, NW Washington, DC 20552 Washington, DC 20429 Docket Number 2006-49 RIN 3064-AC96 Docket Number 2006-33 RIN 3064-AC73 regs.comments@ots.treas.gov comments@FDIC.gov Dear Sir or Madam: State Street Corporation appreciates the opportunity to comment on the proposed U.S. implementation of the “International Convergence of Capital Measurement and Capital Standards: A Revised Framework” (the “New Accord” or “Basel II”) as described by the Notice of Proposed Rulemaking (the “NPR”) published by the Office of the Comptroller of the Currency, the Board of Governors of the ...