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FDIC Federal Register Citations |
From: Jim Franks Sent: Thursday, September 05, 2002 10:08 AM To: Comments Subject: Proposed Rule on Customer Identification Program - FIL 92-2002; August 22, 2002 RE: Proposed Rule on Customer Identification Program FIL 92-2002; August 22, 2002 Gentlemen: So, with all of this having been said, I trust even you can understand that when a 40-year customer of our bank comes in to open a new grandchilds first savings account, and we inform this (older) customer that we must have documentation to prove who she is (not withstanding that we know her), plus documentation to prove who her new grandchild is, our customer will most likely not understand. Even worse, she may even get hostile. Situations like this will give banking another black eye. Rather than make new regulations it would be appropriate to enforce the ones already on the books. I noticed that your proposed regulations claim to have some flexibility for each bank based on the specific banks makeup, size, complexity, situation, etc. However, the flexibility does absolutely nothing for such situations as outlined above. I feel that accommodations should be made for situations in which the customer has been a customer of the bank for such a period of time or is actually known by bank personnel. Secondly, there appears to be no allowances made for government entities. How do we document/prove who the State of Arkansas is; the City of Prescott; or for that matter, the United States of America? The regulations need to be either more specific or make allowances for common sense situations, something regulations rarely do by the way. I appreciate this opportunity to comment on the proposed regulation. Jim Franks |
Last Updated 09/05/2002 | regs@fdic.gov |