May 2, 2005
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th St NW
Washington, DC 20429
Re: EGRPA burden reduction comment
Dear Mr. Feldman:
World’s Foremost Bank (“WFB”) is a Nebraska
state-chartered bank located in Sidney, Nebraska
that is primarily engaged in interstate credit
card lending. WFB appreciates the opportunity to
comment on the FDIC’s Request for Burden Reduction
Recommendations with regard to Money Laundering,
Safety and Soundness and Securities Rules pursuant
to the Economic Growth and Regulatory Paperwork
Reduction Act of 1996 Review.
WFB offers the following suggestions:
Bank Secrecy Act &
Anti-Money Laundering
-
Increase the dollar
threshold under which Currency Transaction Reports
(CTRs) should be filed
to $20,000.
-
Increase the
Suspicious Activity Report (SAR) dollar threshold
for situations in which a subject cannot be
identified from $5,000 to a higher dollar amount.
-
SAR requirements for
situations involving insider abuse should be
clarified by including a dollar amount threshold.
The current levels for reporting
CTRs and
SARs involving
unidentifiable suspects do not reflect today’s
economy. SAR filing for insider abuse involving
small dollar amounts is wasteful of bank resources
and examiner time.
Adjusting dollar figures would allow examiners and
law enforcement to concentrate on valid and
legitimate suspicious activity and avoid
ineffective and superfluous reports.
Community
Reinvestment Act (CRA)
-
Expand the “small
bank” threshold from $250 million to $1 billion.
The current CRA threshold is overly burdensome and
an adjustment to $1 billion would alleviate a
substantial burden on small banks such as WFB.
Customer
Identification Program (CIP) -
USA PATRIOT Act
-
Allow Post Office
Boxes as valid addresses for complying with
Section 326 requirements.
-
Relax the CIP rules to
allow information collection soon after an account
is opened, based on a bank’s overall risk.
The current requirement to collect a physical
address is ineffective because the consumer may
provide other addresses which may be difficult to
verify yet valid. The rule discriminates against
rural consumers whose local Post Offices insist on
Post Office Box addresses for mail delivery.
Requiring information to be collected prior to
account opening limits banking and credit services
offered on a “pre-screen” or “point of sale”
basis. Adjustments to the rule would increase
availability of credit to consumers but pose
little risk of terrorist financing.
Privacy Notice
requirements pursuant to the
Gramm-Leach-Bliley Act (GLBA)
-
Banks shouldn’t have
to send the annual Privacy Notice if there are no
substantial changes to the institution’s privacy
policies or information sharing practices.
Consumers are inundated with annual privacy notice
documents which are ineffective and confusing. If
a bank hasn’t changed its information sharing
activities, it shouldn’t be required to
re-disclose if the consumer has already received
the notice. Annual disclosures only add to
operational costs which are ultimately passed on
to consumers.
Thank you for the opportunity to comment.
Sincerely,
David A. Roehr
President/CEO
World’s Foremost Bank
