From: Robert Lee [mailto:robertl@centralbankhouston.com]
Sent: Thursday, May 05, 2005
1:44 PM
To: regs.comments@federalreserve.gov;
Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
The purpose of this comment is
to address the increased regulatory
burden of the CTR and SAR filings.
The CTR threshold of $10,000.01
has been the same for a long
period of time. Everyone knows
the number. Most bank customers
believe the CTR is used to report
income to IRS. Banks are now
compelled to file CTR’s
on aggregated transactions that
meet the threshold and SAR’s
on the individual deposits that
make up the total. Lowering the
threshold to $5,000 would avoid
this double filing of paperwork.
Most SAR’s are now filed
for structuring of deposits.
The way the customer conducts
business has not changed but
now a defensive SAR is required
to be filed to avoid a violation
and a SAR is required every 90
days on the customer. Banks have
always monitored customers for
suspicious activity not only
because of BSA but because we
don’t want to take a loss.
The interpretation of suspicious
activity has been changed by
the examiners and the banks have
not had a fair chance to prepare
for the ramifications of that
change.
Robert Lee
Central Bank
Houston TX
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