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Community Bank of Florida
Gentlemen:
As requested,
we offer comment specifically on the Bank Secrecy Act.
Like all
other Florida bankers, we would request clarity and consistency regarding
this Act. We have our hesitation in closing long-term accounts due to the
perceived BSA risk associated with them. Where are these people going to
bank? Examiners make it very clear that these businesses are not going to
do business with a bank they have audited. It seems that the Examiners
were sent on a mission with little guidance and are making up rules. With
the penalties and fines that have been assessed, the penalties appear
excessive.
Because we
want to do what we think is required, we have spent over $100,000 to
implement software that we hope will be satisfactory to comply with this
Act. Each year, the software will require upgrades so the cost continues,
plus personnel and overhead.
Are you sure
you are doing the right thing?
Robert L. Epling
President
Community Bank of Florida
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