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

Comment

 


From: crodrigue [mailto:crodrigue@cbexpress.com]
Sent: Monday, February 14, 2005 9:23 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov
Subject: EGRPRA

Hi

I am writing regarding the Economic Growth and Regulatory Paperwork Reduction Act request for comments.

I would like to submit the following comments on Bank Secrecy Act, USA Patriot Act, and Extensions of Credit to Insiders and Regulation O:

Bank Secrecy Act -

--
Increase the threshold for transactions requiring CTRs from $10,000 to a higher amount.
-- Increase the threshold for monetary instruments from $3,000 to a higher amount.
-- Eliminate annual recertification requirements for the same “exempt” customers
-- Increase the threshold for money laundering SARs from $5,000 to a higher amount.
-- Establish a dollar threshold for insider abuse, eliminating SARs for small dollar theft.

USA Patriot Act and "Know Your Customer" Requirements:

-- Provide clear guidance regarding the customer identification standards such as what is considered an acceptable form of identification?

Extensions of Credit to Insiders and Regulation O:

-- Eliminate certain reporting requirements such as:

-- A report filed by a bank executive officer with the bank’s board of directors whenever the executive officer obtains a loan from another bank in an amount that exceeds the amount the executive officer could obtain from his or her own bank;

-- An annual report from a bank’s executive officers and principal shareholders to the board of directors of any outstanding loans from a correspondent bank.

-- Increase limits on inadvertent overdrafts from the current level of $1,000.

Charles Rodrigue
Community Bank, Raceland, LA

 
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