From:
Michelle Huddleston [mailto:mhuddleston@cbtn.com]
Sent: Monday, February 28, 2005 11:06 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
The
recent emphasis placed on BSA and the expanded examination
procedures are smothering the small business that
makes up 90% of our customer base. The expected monitoring
level that we are being forced to live up to is pushing
the limit of our customer relations and forcing us
to make decisions to cut business ties with good
long-standing customers simply because we can't take
the regulatory risk. The monitoring of business profiles
and MSBs is taking a full time person. I agree that
banks should act responsible and be alert to improper
and immoral activity of our customers, but these
requirements do not cause this to happen. Emphasis
should be placed on International Wire Transfer Departments
and not small business. We can wire money anywhere
in the world with as little as an account number.
But yet we are required to dig through our local
Mom and Pap's grocery store deposit to determine
if they cashed a check for $1,000. If MSB monitoring
is so important there should be a branch of government
assigned to regulate them directly - not force us
to do your dirty work. We are big enough to survive,
but this surely must be a loss situation for a smaller
bank.
Have
a Great Day!
Michelle
Huddleston
Senior Vice President
Commercial Bank
PO Box 400
Harrogate TN 37752
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