From: Phillipy, David [mailto:PhillipyD@MonroeBank.com]
Sent: Thursday, February 03, 2005 1:44 PM
To: 'regs.comments@federalreserve.gov'; Comments; 'regs.comments@occ.treas.gov';
'regs.comments@ots.treas.gov'
Subject: EGRPRA - BSA/AML Two primary ways to reduce time/red tape:
1. Increase the CTR reporting threshold to $15,000 or $20,000. (There
has
been no "cost of living" adjustment since the 1960's.)
2. Reduce the MSB due diligence requirements of financial institutions.
It
should not be a requirement of financial institutions to monitor the AML
program of MSBs. This should be a federal regulatory matter. The
agencies
need to stop relying on banks to enforce federal rules and regulations
that
are outside our direct control. The time and costs of this provision
will
be astronomical! (We are already obligated to manage our own BSA/AML
program and the requirements in this area have grown exponentially. We
should only be held accountable for what is under our direct control!)
Thank you for your consideration.
Monroe Bank
David A. Phillipy, CRCM
Vice President, Compliance and CRA Officer
210 E. Kirkwood Avenue
Bloomington, IN
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