From: Ratna Ray [mailto:rray@rockvillebank.com]
Sent: Friday, April 16, 2004 2:35 PM
To: Comments
Subject: EGRPRA burden reduction comments
GLBA- The act as it states puts tremendous amount of work on bank's
part to be in
compliance. Not only that, it requires enormous amount of paper work as supporting
documents for verification by regulatory examiners.
REG E- This Regulation
requires too many correspondence with customers to be in
compliance, specially on Debit card issues while card holder has no
liability
for unauthorized transactions. Merchants also have very little
liability.
The way the REG E is formulated now, the complete financial burden is on the
bank as merchants do not verify the cardholder's identity. Card holders do
not report promptly the loss of the card. The regulation should be
revised to have the bank liable for only within 24 hours preceding the notification
of the last card.
REG D- Presently the Regulation does not allow more than six transactions
total of six preauthorized and electronic during 30 day period on
a Statement Savings Account.
This regulation was enacted long before Internet banking was popular.
Now with
more and more customers using electronic banking, this limitation is a burden
on the bank as it requires monitoring, documenting, correspondence with
customers and take action as necessary. Moreover, it is an impediment to the
utilization of electronic banking which we all try to promote. This limitation
should be removed or relaxed to a larger number of transactions