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From: Becky Berning [mailto:bberning@firststatebanksw.com]
Sent: Friday, October 15, 2004 3:55 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
First State Bank Southwest
To Whom It May Concern:
Thank you for giving the financial institutions an opportunity to
comment on the regulations.
Please consider the following points:
Regulation B – “Evidence of Intent to Apply for Joint
Credit”
This requirement seems unnecessary. If the application is completed
as a joint application, that should be sufficient proof that it was
the intent to apply for joint credit.
Regulation D – Limitation on Transfers from Money Market Deposit
Accounts
This has placed restrictions on banks to be less competitive with
non-banks and credit unions. It causes a lot of paperwork for the
banks.
Regulation P – Privacy Notices
The only time a bank should have to provide this notice to the customer
is when the bank’s policy has changed. The majority of the
customers do not pay any attention to the notice when received. It
is an unnecessary expense to the bank.
Regulation E – Electronic Fund Transfers
Consumer liability from unauthorized transactions resulting in the
neglect of the customer, such as writing the PIN number on the card,
giving the card & PIN number to someone over the Internet, etc.,
should be increased. It is not fair to the banks to have to lose
money in every instance for the unauthorized transactions. The customer
should have to pay for their irresponsible actions.
Consumer Protection in Sales of Insurance
The disclosures required by these regulations do not fit certain
products, including credit life and related products, crop and flood
insurance. The focus of the rule should be on the insurance products
that are similar to a deposit product and that a consumer might confuse
with a deposit that is FDIC insured. This is burdensome to the bankers
and confusing to the consumer.
Thank you for the opportunity to comment.
Sincerely,
Becky Berning
Audit/Compliance
First State Bank Southwest
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