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FDIC Federal Register Citations
From:
Reta Davis [mailto:davisr@bakerboyer.com]
Sent: Friday, February 04, 2005 11:43 AM To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov Subject: EGRPRA 1.The Anti-Money laundering rules are necessary but the level of documentation required is overly burdensome. In our last OCC exam we were advised to keep a binder of records on SAR Suspects No Report filed. This I guess was to show we are alert. The rules of when to file a SAR, and common sense should be enough. It seems silly to have to keep a file on all the situations we check out that do not have enough merit to file a SAR. 2. The registration requirements of MSBs has merit. The documentation we are required to keep on small accounts that occasionally cash checks totaling $1000.00 is very time consuming. I think the rules should be changed to read if the business cashed checks totaling over $1000.00 as a standard practice of their business:.
Reta Davis
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Last Updated 02/07/2005 | Regs@fdic.gov |