I am writing on behalf of the Virginia Bankers Association
(the “VBA”) to comment on the agencies’ notice
pursuant to the Economic Growth and Regulatory Paperwork
Reduction Act seeking suggestions on ways to reduce burden
in rules relating to money laundering, safety and soundness,
and securities. The VBA represents nearly all of
the commercial banks and thrifts (collectively “banks”)
doing business in the Commonwealth of Virginia. The
VBA currently has 161 members. Its membership includes
many small banks serving local communities, as well as
a number of large banks with a multi-state or nationwide
presence.
The VBA’s comments relate to money laundering rules. Our
banks want to do their part to fight terrorism and prevent
money laundering. However, they are very concerned
about the costs and burdens associated with the current
reporting system. Indeed, the Bank Secrecy Act
represents perhaps the greatest and costliest compliance
challenge currently facing our banks. The costs
and burdens are especially significant for our smaller
bank members which do not have the same resources to
devote to compliance that the larger banks have.
We therefore recommend that the agencies seek to reduce
costs and burdens associated with money laundering rules. One
way to do so is to provide clearer guidance on what is
required under the law. Our banks have complained
that specific and uniform guidance from the agencies
has been lacking. This has created confusion and
uncertainty for our banks, which obviously has driven
up costs.
Another way to reduce costs and burdens involves changing
the rules to reduce the number of “defensive” filings
of suspicious activity reports (“SARs”). Currently,
banks are filing thousands of SARs that have no value
to law enforcement, simply because they fear liability
for failing to do so. Such filings impose a considerable
cost on banks. The agencies need to work to eliminate
these unnecessary filings so that more of our banks’ resources
can be put to productive use.
Finally, we recommend raising the threshold for currency
transaction reports (“CTRs”) from $10,000
to $20,000. This would eliminate a significant
number of filings which are of little or no value to
tracking money laundering activities.
In sum, the VBA encourages the agencies to act vigilantly
to reduce burdens in this area of compliance. The
success (and indeed the survival) of our banks depends
on it.
Sincerely,
Walter C. Ayers
President and CEO
Virginia Bankers Association
menu item:About EGRPRA, sub menus under About EGRPRA Are:
What is EGRPRA?
Why Is EGRPRA Important?
Why Should Bankers and Consumers Comment?
The Law
menu item:Comments and recommendations, sub menus under Comments and recommendations Are:
Submit Comments & Recommendations
Read Comments & Recommendations
menu Item: Communications, sub menus under Communicatons Are:
What We Are Doing To Reduce Burden
Banker's Top Ten Issues - 2003
Press Releases
Comments, Quotes and news
Federal Register Notices
menu item Outreach events, sub menus under Outreach events are:
2003 - 2004 Map
menu item:About Agencies, sub menus under Agencies Are:
FFIEC
FDIC
FRB
OCC
OTS
NCUA
