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From: Deb Herchenbach
[mailto:dherchenbach@farmersstatebank.info]
Sent: Friday, October 15, 2004 3:21 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
The following points
are being made in response to the request for comments on Consumer
Protection and Account/Deposit Relationships:
-Consumer Protection
in Sales of Insurance – This merely creates additional paperwork
and does not serve to inform the public in any way. Because there
are so many numerous disclosures required with consumer lending,
this additional disclosure just adds to the paperwork burden. In
trying to protect the consumer, they are paradoxically confused by
the barrage of disclosures which have no real meaning to the average
consumer.
-Privacy of Consumer
Financial Information – The annual privacy disclosure is routinely
discarded by many consumers. Consumers receive numerous privacy statements
from various companies which are ignored because each privacy statement
says virtually the same thing. Another example of regulatory overkill.
-Disclosures required
by the EFT and Truth in Savings regs are too lengthy and most likely
are not read by the consumer.
In general, I feel that too much emphasis is placed on required policies for
banks. I run an 18 million dollar bank and have three employees. At our
last FDIC exam, the examiners stated that we were doing what was required
in the areas of BSA and Safeguarding Customer Information, however we needed
to better document what we are doing in policies. Perhaps small banks should
be exempt from some of these policy requirements in an attempt to lessen
the burden – particularly when we are doing what is required on a
day to day basis.
I strongly feel
that small banks are unduly burdened by regulatory requirements and
exemptions for well-run small banks should be implemented. The insurmountable
task of trying to comply with the myriad of rules and regs is threatening
the survival of small banks in this country.
Deb Herchenbach,
President
Farmers State Bank
Humphrey, NE
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