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From: Diane Foltz
Sent: Tuesday, September
14, 2004 12:59 PM
To: Comments
Subject: EGRPRA Burden Reduction
Dear Mr. Feldman:
I appreciate the opportunity to comment on the efforts
to reduce regulatory burden in our industry. I represent
a $437 million community bank with seven offices in
our county. Please consider the following in regards
to your request:
Regulation H: We feel that getting the credit disclosure
signed within three days is particularly burdensome.
Many of our applications are taken over the phone and
credit insurance is solicited at that time. Disclosures
are sent within three days but are rarely signed and
returned, especially if the loan is not originated.
It is difficult and costly to send letters and make
calls in an effort to get the disclosure returned.
This disclosure should be eliminated and replaced with
a disclosure signed at closing confirming the purchase
of the insurance. However, even that seems to duplicate
the requirements Regulation Z sets forth for the purchase
of optional insurance. It does not feel, with today's
requirements, that we are providing service to our
customers when we require them to sign three disclosures
(credit, insurance and Reg Z confirmation) just to
confirm the purchase of insurance in connection with
a loan on top of the forms required by the insurance
company.
Regulation P: As stated in several other comment letters,
the annual notice requirements for the privacy notices
are very costly to our community banks, especially
when the notice has not changed from the previous mailing.
Giving consumers a notice at account opening and any
time there is a change should be sufficient. Please
remember that institutions have this notice on their
website for consumers to review at their convenience
in the event they need to. The annual mailing requirement
could also be replaced with a lobby notice requirement.
Again, with the website notice and a lobby notice,
those interested would have multiple ways to access
the notice while providing institutions with a substantial
cost savings. We also oppose any amendments to the
content or form of the notice that would make the requirements
under the regulation more burdensome.
Safeguarding of Customer Information: Several areas
here are burdensome and costly for community banks
to comply with. Risk analysis, documentation requirements
and vendor due diligence requirements are good examples.
We understand that there is no "one size fits
all" answer here, however the guidelines provide
very little assistance in these areas leaving banks
scrambling. Commentary and/or clarity of intent would
be helpful here.
Regulation E: The quarterly statement requirement
for savings accounts that have EFT capabilities but
no EFT activity is a costly burden. We ask that you
consider allowing savings account statements which
have no EFT activity to be moved to a semi-annual or
annual statement cycle.
Thank you for allowing us to comment on this topic.
We hope to see action taken towards reducing regulatory
burdens in our industry in the near future.
Sincerely,
Diane M. Foltz
Farmers State Bank
Compliance Officer
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