| From: Wendy
Parker [mailto:wparker@BankofUtah.com]
Sent: Friday, February 25, 2005 5:26 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
I would like to submit the following comments on
Bank Secrecy Act, Anti Money Laundering and Regulation
D Transaction Limitations.
BSA/AML –
It is far past time to reevaluate the CTR and monetary
instrument transaction amounts. The amounts are no
longer reasonable as they were when initially established.
I believe these limits should be raised to at least
$25,000 and $10,000 respectively. The current limits
cause reporting of transactions to the extent that
they become burdensome to both the banks that complete
them and the agencies that review. This excessive
reporting diminishes the purpose of the law and makes
it less effective.
The biennial renewal of exempt customers is a redundancy.
We are required to monitor annually and that process
should be sufficient.
Twelve months is too long before a customer can
be granted an exemption. If a well established business
in our area (i.e. grocery store) moves an account
from one bank to another our assessment as to the
nature and legitimacy of this business should be
sufficient to exempt the customer somewhere in the
three to six month range. Otherwise we are filing
CTR’s daily and once again defeating the purpose.
There definitely must be examination guidelines.
The examination process has become a stress-full
anticipation of the unknown, resulting in defensive
filing patterns. Examiners insist that customers
must be assessed and monitored for risk but offer
no more assistance than those that are non-exemptible
must be high risk. I beg to differ that all non-exemptible
customer types are high risk customers.
Reg D –
The transaction limitation on money market savings
accounts needs to be removed. This is a regulation
that no longer fits in with today’s technology.
With the offering of electronic banking we give our
customers the freedom to manage their funds and then
take it away with these outdated restrictions.
Thank you for the opportunity to comments on these
issues.
Wendy B. Parker
V.P. Banking Operations Manager
Bank of Utah
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