From: Jacobs, William [mailto:wjacobs@anchorbank.com]
Sent: Thursday, February 03, 2005 2:05 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA Documentation and information necessary for CIP and OFAC
Compliance should be combined onto one form so as to reduce the
redundancy of collected materials. Having a single form that
specifically outlines necessary information and the documentation
appropriate for its verification would not only save paper through the
non-repetitive warehousing of like documents, it would also reduce the
labor intensive nature of the current process. Above and beyond the
paper and time saving advantages of using one form, would be the
unintended, but beneficial consequence of reducing reporting errors.
Imagine - one form that provides specific guidance and direction as to
what is adequate, complete, and correct information. Imagine further -
the same form giving specific guidance and direction on what is
necessary and appropriate for information verification. At present, the
trend is to collect and re-collect and then verify and re-verify in an
attempt to ensure adequacy - this may seem like good policy, however it
neglects the old axioms of efficiency and effectiveness in resource
management.
Respectfully,
William R. Jacobs, JD, MBA
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