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FEDERAL RESERVE SYSTEM july 30, 2015 Mr. Matthew Lee, Esq, Inner City Press P.O. Box 20047 ‘New York, NY 10017 Re: Freedom of Information Act Request No. F-2015-0309 Dear Mr. Lee: This is in response to your electronic message dated and received by the Board’s Freedom of Information Office on July 24, 2015. Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § $52, you requested information relating to the Application by Community Bank System, Inc. (“CBSI") to acquire Oneida Financial Corp. (“Oneida”). Specifically, you seek “the exhibits that [CBSI] has claimed are confidential in CBSI's July 20 response to the FRB's July 13 questions. ..." "You were previous y provided with a copy ofthe public portion of the Additional Information (“AI”) Response from CBSI dated July 20, 2015. Accordingly, staff searched Board records and located the confidential exhibits t© this AI Response. Ihave determined that all ofthe exhibits that were designated as “confidential” can be released to you in full, except that the portions of Confidential Exhibit 4 cortaining confidential business information relating to CBST’s due diligence investigation of, and negotiations with, Oneida are exempt from disclosure, This infermation is subject to withholding and will be withheld pursuant to exemption 4 of the FOIA, 5 U.S.C. § 552(6\4). Confidential Exhibit, {has been reviewed under the requirements of subsection (b) of the FOLA, 5 USCC. § 552(b), and all reasonably segregable nonexempt information will be ‘made available t0 you. ‘Your request for information, therefore, is granted in part and denied in part for the reasons stated above. The document being released to you will indicate the amount of information that has been withheld and the applicable exemption. If you believe you have a legal right to any information that is being withheld, you ‘may appeal this determination. Very tly yours, sonata en Deputy Serer of he ead "please not that an appeal its be ied (that is, receive by the Board) within 10 working days ofthe daton which the denial was issued or the date on which document in partial response fo the request were transmitted te you, whichever i ater. You may submit your appeal by mail, fesse to the Freedom of Irformation Orfice, Board of Governors ofthe Federal Reserve ‘System, 20th Steet & Consttton Avenue NW, Washington, D.C. 2051; by facsimile, to 202- '872-7565; o electronical, to FOLA-Appeals@ith gov. Please be aware tht submiting an appeal ty postal mail ean rest in delays due 10 mail processing. The Boards regulations regarding FOIA appeals are located at 12 CFR. § 261.130)

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