Federal Deposit
Insurance Corporation

°   I understand the reasoning behind the increased identity concerns although I don't understand the objective of collecting and retaining identity information on persons seeking to open an account. We would have no reason to keep information on someone who does not do business with our bank and keeping the information for 5 years could create storage issues.

If the government wanted to know if a certain person applied for an account with our financial institution we would not have any record of the non-customer on our Customer Information Files therefore would have a difficult time retrieving the information.

°   I appreciate the fact that we are not going to be required to obtain identity information each time an existing customer opens a new account however, the proposal seems to indicate that customers who were existing prior to 10/26/02 and want to open an additional account would have to endure the identification procedures. This means that we would have to properly identify a customer that has done business with us for 20 years just because he wants to open another account. It also means that we will not have identifying information on someone who opened an account prior to 10/26 and never opens another account. This seems to lack consistency.

I recommend that banks would be permitted to assume that the customer is known by the financial institution and therefore, is exempt from the identification procedures if they have been a customer, without interruption, for five years or more.

°   Although many of the concepts illustrated in Section 326 are already practiced at most financial institutions, I still have concerns about the timing of implementation. The comment period for this proposal ends on August 31, 2002, leaving only 55 days for the final regulation to be issued and for financial institutions to revise their policies and procedures and train employees. A more reasonable effective date would be March 31, 2003.

The specific segments of the proposal referred to in the first two bullet points above, would be burdensome and unreasonable to the financial institution with seemingly little benefit to the government in achieving the goal of preventing and detecting money laundering and terrorism financing. In the third bullet point, I am requesting an extension on the implementation date to March 31, 2003.

Thank you for your consideration of these comments.

Sincerely,