From: Mari Coonley
Sent: Monday, June 23, 2003 10:00 AM
To: Comments; regs.comments@federalreserve.gov; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
I have only been in the banking industry for one year and the concept
of duplicate reporting boggles my mind. The Call Report (FDIC) and
the FRY-9 (FRS) are practically identical, with the exception of the
FRY-9 including holding company data...which is a relatively
immaterial level of variance. These two reports even have similar
designation in relation to the notation of balance sheet (RC on the
Call Report and HC on FRY-9) as well as all other sections. These two
reports are then compared to each other for discrepancies. Why is
there not just ONE report that both FDIC and FRS can share? I
received a notice from the FDIC regarding the creation of a shared
data base, does this also imply that there will be the consolidation
of reporting also? or have I misunderstood the implication?
While I am not a seasoned banker, I have found that my insights as a
novice to this industry have proved to be of some value to my
co-workers as we have worked diligently to increase our efficiency and
eliminate unnecessary duties within our own bank. I've also learned
that there ARE legitimate reasons for performing duties that to an
outsider seem unnecessary, perhaps this is the case with these
reports. Either way, at least I've voiced my opinion. Although, I
would be interested to know the purpose of the two separate reports.
