To the Editor:

I would like to clear up a misperception the American Banker article "Foreign Trade Pact Loopholes Seen Hampering U.S. Banks," Jan. 14, may have conveyed regarding Bank of America's position on the recently completed (World Trade Organization) Financial Services Agreement.

As I clearly indicated in my prepared remarks and throughout the panel discussion during the Coalition of Service Industries' seminar on the Geneva talks, Bank of America strongly supports the Financial Services Agreement.

By guaranteeing the acquired rights of foreign banks in over 60 countries, the right of new bank establishment in 59, the ability to directly branch in 42 countries, and 100% ownership of bank subsidiaries in 41, the Financial Services Agreement unquestionably protects the interests of U.S. banks with foreign operations and provides significant opportunities for those who seek access to these markets.

It also establishes an excellent template for the financial services component of the WTO accession agreements for such important countries as China, Russia, and Taiwan.

It is unfortunate that your story focused on those few remarks by my colleagues and me concerning the agreement's shortcomings.

No negotiated trade agreement can be perfect from one party's standpoint, and we expect that the United States will vigorously address the remaining problems in the next GATS round.

But these reservations clearly do not diminish our support for this agreement, which sets a strong and necessary foundation for future negotiations.

To interpret Bank of America's position otherwise distorts the record and does your readers a disservice.

Thank you.

Robert D. Kramer

Vice presidentBank of AmericaSan Francisco

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