SECURITY BANK
From: Tressa Jacobs
Sent: Friday, July 23, 2004 3:17 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA - Comment Letter - Reducing Regulatory Burden- Consumer
Protection- Regulations
To Whom It May Concern:
Your efforts in attempting to reduce regulatory burden on financial
institutions are applauded. I appreciate the opportunity to comment
on these issues.
Please consider the following points:
Regulation B/Equal
Credit Opportunity Act – “Evidence
of Intent to Apply for Joint Credit”
This requirement appears redundant and without merit. A person’s
signature should suffice for evidence that they are applying for
joint credit.
Regulation D – Limitations
on Transfers from Money Market Deposit Accounts.
The restrictions place banks at a competitive disadvantage with non-banks
and credit unions. Mover the regulation is antiquated and serves
no apparent purpose.
Regulation P – Privacy
Notices
Providing annual notices to customers is inefficient and confusing.
Annual notices should not be sent unless the privacy policies have
changed.
Regulation BB – Community
Reinvestment Act
Again, banks are put at a competitive disadvantage since non-banks
and credit unions are not subject to the same requirements. The
small bank threshold should be raised from $250 million to $1 billion.
Regulation Z/
Truth in Lending – Right to Rescind
Bank customers have difficulty understanding why they must wait for
the funds when refinancing a mortgage or obtaining a home equity
loan. They are often frustrated why the have to wait three days
before receiving their loan proceeds. This requirement is an unnecessary
burden on the lender, borrower and possibly a third party to whom
the loan proceeds may be going.
Burden on Small Insured Institutions
While the intent of consumer protection regulations is noble, the
effectiveness must be questioned. Many provisions of Consumer Protection
Regulations should be eliminated or drastically reduced in order
to minimize customer confusion ,the significant economical impact
the regulations have on a substantial number of small institutions
and an unfair disadvantage to the banking industry compared to
non-bank businesses.
Hopefully the outcome of these solicited comments will be a simplification
to these regulations that will benefit both the consumer and the
bank.
Respectfully,
Tressa Jacobs
Compliance Officer
Security Bank
204 W. Washington Street
P.O. Box 1209
Paris, TN 38242
|