April 12, 2005
Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 - 17th Street, NW.
Washington, DC 20429
Re: Reducing Regulatory Burden Money Laundering,
Safety and Soundness and Securities Rules
Dear Mr. Feldman:
We are pleased to submit
comments on reducing regulatory burden relating to Money Laundering,
Safety and Soundness, and Securities Rules. The regulations enacted
pursuant to the Bank Secrecy Act and anti-money laundering are our most
burdensome regulations. Below are our recommendations to alleviate the
burden without impacting the intent of the regulations:
Money Laundering - Increase the threshold for
transactions requiring CTRs from $10,000 to $25,000. The $10,000
threshold has not been changed since it was established in 1979. Back
then cash transactions over $10,000 were an infrequent event, now it is
common to process these types of transaction and it causes a burden due
to the large number of CTRs that must be filed.
Money Laundering - Eliminate the biennial
renewal of Phase II exemptions. Permit the initial exemption to
continue until the bank determines that the customer’s attributes no
longer qualify for exempt treatment. In addition, because the annual
review of eligibility status must be done, it appears to be redundant to
require the bank to file a biennial renewal document.
We appreciate the
opportunity to participate in this endeavor to reduce outdated, unnecessary
and unduly burdensome regulatory requirements.
