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SECURITY
BANK
From: Tressa Jacobs
Sent: Friday, July 23, 2004 3:17 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA - Comment Letter - Reducing Regulatory Burden- Consumer Protection-
Regulations
To Whom It May
Concern:
Your efforts in
attempting to reduce regulatory burden on financial institutions
are applauded. I appreciate the opportunity to comment on these issues.
Please consider
the following points:
Regulation B/Equal
Credit Opportunity Act – “Evidence of Intent to Apply
for Joint Credit”
This requirement appears redundant and without merit. A person’s signature
should suffice for evidence that they are applying for joint credit.
Regulation D – Limitations
on Transfers from Money Market Deposit Accounts.
The restrictions place banks at a competitive disadvantage with non-banks and
credit unions. Mover the regulation is antiquated and serves no apparent purpose.
Regulation P – Privacy
Notices
Providing annual notices to customers is inefficient and confusing. Annual
notices should not be sent unless the privacy policies have changed.
Regulation BB – Community
Reinvestment Act
Again, banks are put at a competitive disadvantage since non-banks and credit
unions are not subject to the same requirements. The small bank threshold should
be raised from $250 million to $1 billion.
Regulation Z/ Truth
in Lending – Right to Rescind
Bank customers have difficulty understanding why they must wait for the funds
when refinancing a mortgage or obtaining a home equity loan. They are often
frustrated why the have to wait three days before receiving their loan proceeds.
This requirement is an unnecessary burden on the lender, borrower and possibly
a third party to whom the loan proceeds may be going.
Burden on Small
Insured Institutions
While the intent of consumer protection regulations is noble, the effectiveness
must be questioned. Many provisions of Consumer Protection Regulations should
be eliminated or drastically reduced in order to minimize customer confusion
,the significant economical impact the regulations have on a substantial number
of small institutions and an unfair disadvantage to the banking industry compared
to non-bank businesses.
Hopefully the outcome
of these solicited comments will be a simplification to these regulations
that will benefit both the consumer and the bank.
Respectfully,
Tressa Jacobs
Compliance Officer
Security Bank
204 W. Washington Street
P.O. Box 1209
Paris, TN 38242
43347-43351
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