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
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