From: Robert Lee [mailto:robertl@centralbankhouston.com]
Sent: Thursday, May 05, 2005 1:44 PM To: regs.comments@federalreserve.gov; Comments;
regs.comments@occ.treas.gov; regs.comments@ots.treas.gov Subject: EGRPRA
The purpose of this comment
is to address the increased regulatory burden of the CTR and SAR
filings. The CTR threshold of $10,000.01 has been the same for a
long period of time. Everyone knows the number. Most bank
customers believe the CTR is used to report income to IRS. Banks
are now compelled to file CTRs on aggregated transactions that
meet the threshold and SARs on the individual deposits that
make up the total. Lowering the threshold to $5,000 would avoid
this double filing of paperwork. Most SARs are now filed for
structuring of deposits. The way the customer conducts business
has not changed but now a defensive SAR is required to be filed
to avoid a violation and a SAR is required every 90 days on the
customer. Banks have always monitored customers for suspicious
activity not only because of BSA but because we dont want to
take a loss. The interpretation of suspicious activity has been
changed by the examiners and the banks have not had a fair
chance to prepare for the ramifications of that change.