EGRPRA


EGRPRA Home
What Are We Doing
Top Ten Issues
Read Comments
Site Map
Search EGRPRA

blue image
Economic Growth and Regulatory Paperwork Reduction Act with EGRPRA logo on left side

Comment

 


From: Dennis Burnette [mailto:DennisBurnette@cherokeebank.com]
Sent: Sunday, February 13, 2005 10:07 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov
Subject: EGRPRA


USA Patriot Act and "Know Your Customer" Requirements:

Bank regulators should ask Congress to repeal the customer identification and recordkeeping requirements of the USA Patriot Act. It should be obvious by now that all the paperwork is not effective in catching terrorist are preventing terrorism.

Regulation D - Limitations on Transfers from Money Market Deposit Accounts:

This regulation prevents banks from competing and offering the same product to its corporate clients as offered by brokerage houses. In addition to being ant-competitive, it serves no safety and soundness purpose. The limit to number of withdrawals should be eliminated.

Community Reinvestment Act (CRA) Regulations:

This may have been needed at one time but today it is merely paperwork and does nothing to promote community bank lending. At a minimum, the threshold should be increased to $1 Billion in assets.

Truth-in-Lending - Right of Rescission:

This regulation is a joke. I’ve been a banker longer than this regulation has been around and I have never seen a consumer exercise this “right”. My experience is that consumers see this as not a “right” but a taking of their liberty, or ability, to receive their loan proceeds.

Privacy Notices:

This regulation does nothing but increase the costs that are passed on to consumers. Nothing needs to be done beyond, perhaps, a disclosure when the account is opened. Frankly, that may not be read either.

Truth in Lending (Reg. Z) and, RESPA:

Our mortgage clients don’t understand all the documents they have to sign. These regulations make borrowing more complex to our clients. The regs should be completely rewritten.

Flood Insurance:

Commercial loan transactions should be exempted.

Dennis Burnette
President
Cherokee Bank
PO BOX 4250
Canton. GA 30114

 
menu item:About EGRPRA, sub menus under About EGRPRA Are: What is EGRPRA? Why Is EGRPRA Important? Why Should Bankers and Consumers Comment? The Law menu item:Comments and recommendations, sub menus under Comments and recommendations Are: Submit Comments & Recommendations Read Comments & Recommendations menu Item: Communications, sub menus under Communicatons Are: What We Are Doing To Reduce Burden Banker's Top Ten Issues - 2003 Press Releases Comments, Quotes and news Federal Register Notices menu item Outreach events, sub menus under Outreach events are: 2003 - 2004 Map menu item:About Agencies, sub menus under Agencies Are: FFIEC FDIC FRB OCC OTS NCUA