Federal Deposit
Insurance Corporation

Subject: fil-92-02

Gentlemen:

Thank you for the opportunity to comment on the proposed rule on Customer Identification Program.

Under the proposal the bank would be required to obtain a U.S. taxpayer identification number. Under the present regulations we may open accounts without a ssn as long as we document the accounts affected and provide a listing upon request.

There is a number of religious ministries who, because of their beliefs do not have a TIN or EIN.

I feel that the proposal should enable banks to continue to open non-interest bearing accounts without obtaining a government taxpayer identification number, with the understanding that there would be other avenues to determine the identity, capacity and authority of the customer.

Another item that I would like clarification is, will a Post Office Bos number suffice for the required information? 

In closing, I can assure you that as a bank, we pride ourselves on knowing our customer.

Thank you again for the opportunity to comment.

 Respectfully,