Federal Deposit
Insurance Corporation

 

May 2, 2005

 

 

Robert E. Feldman, Executive Secretary

Federal Deposit Insurance Corporation

550 17^th St NW

Washington, DC 20429

 

 

Re: EGRPA burden reduction comment

 

Dear Mr. Feldman:

 

World’s Foremost Bank (“WFB”) is a Nebraska state-chartered bank located in Sidney, Nebraska that is primarily engaged in interstate credit card lending.  WFB appreciates the opportunity to comment on the FDIC’s Request for Burden Reduction Recommendations with regard to Money Laundering, Safety and Soundness and Securities Rules pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996 Review.

 

WFB offers the following suggestions:

 

Bank Secrecy Act & Anti-Money Laundering

 

-        Increase the dollar threshold under which Currency Transaction Reports (CTRs) should be filed to $20,000.

-        Increase the Suspicious Activity Report (SAR) dollar threshold for situations in which a subject cannot be identified from $5,000 to a higher dollar amount.

-        SAR requirements for situations involving insider abuse should be clarified by including a dollar amount threshold.

 

The current levels for reporting CTRs and SARs involving unidentifiable suspects do not reflect today’s economy.  SAR filing for insider abuse involving small dollar amounts is wasteful of bank resources and examiner time.

 

Adjusting dollar figures would allow examiners and law enforcement to concentrate on valid and legitimate suspicious activity and avoid ineffective and superfluous reports.    

 

Community Reinvestment Act (CRA)

 

-        Expand the “small bank” threshold from $250 million to $1 billion.

 

The current CRA threshold is overly burdensome and an adjustment to $1 billion would alleviate a substantial burden on small banks such as WFB.

 

Customer Identification Program (CIP) - USA PATRIOT Act

 

-        Allow Post Office Boxes as valid addresses for complying with Section 326 requirements.

-        Relax the CIP rules to allow information collection soon after an account is opened, based on a bank’s overall risk.

 

The current requirement to collect a physical address is ineffective because the consumer may provide other addresses which may be difficult to verify yet valid.  The rule discriminates against rural consumers whose local Post Offices insist on Post Office Box addresses for mail delivery.

 

Requiring information to be collected prior to account opening limits banking and credit services offered on a “pre-screen” or “point of sale” basis.  Adjustments to the rule would increase availability of credit to consumers but pose little risk of terrorist financing.

 

Privacy Notice requirements pursuant to the Gramm-Leach-Bliley Act (GLBA)

 

-        Banks shouldn’t have to send the annual Privacy Notice if there are no substantial changes to the institution’s privacy policies or information sharing practices.

 

Consumers are inundated with annual privacy notice documents which are ineffective and confusing.  If a bank hasn’t changed its information sharing activities, it shouldn’t be required to re-disclose if the consumer has already received the notice.  Annual disclosures only add to operational costs which are ultimately passed on to consumers. 

 

Thank you for the opportunity to comment.

 

Sincerely,

 

David A. Roehr

President/CEO

World’s Foremost Bank