Engagement letters ABA comment letter final June 2005

- d & June 9, 2005 Donna J. er FFIEC :xaF202-828 -4548 Program Coordinator 3501 Fairfax Drive Room 3086 Arlington, VA 22226 Via email: FFIEC-comments@FDIC.gov Re: Proposed “Interagency Advisory on the Unsafe and Unsound Use of the Limitation of Liability Provisions and Certain Alternative Dispute Resolution Provisions in External Audit Engagement Letters”; 70 Federal Register 24576; May 10, 2005 Dear Sir or Madam: The American Bankers Association (ABA) appreciates the opportunity to comment on the proposed “Interagency Advisory on the Unsafe and Unsound Use of the Limitation of Liability Provisions and Certain Alternative Dispute Resolution Provisions in External Audit Engagement Letters”. The ABA, on behalf of the more than 2 million men and women who work in U.S. banks, brings together all categories of banking institutions to best represent the interests of this rapidly changing industry. Its membership — which includes community, regional and money center banks and holding companies, as well as savings associations, trust companies and savings banks — makes ABA the largest banking trade association in the country. We share your concern about the impact of limitation of liability provisions and certain types of alternative dispute resolution (ADR) provisions in engagement letters. We became concerned about these types of provisions last fall, when some ABA members who had agreed to ...