SUNTRUST July 21, 2004 Robert E. Feldman Executive Secretary, Federal Deposit Insurance Corporation 500 17th Street, N. W. Washington, DC 20429 Via e-mail: regs.comments@FDIC.gov Reference: Federal Register/Vol. 69, No. 110 Proposed Amendment to 12 CFR 327.2 To Modernize and Simplify the Certified Statement Process Dear Mr. Feldman: SunTrust Banks, Inc. (SunTrust) appreciates the opportunity to comment on the proposal to obtain certified statements on the Internet via the FDIC’s transaction-based e-business web site. SunTrust Banks, Inc., headquartered in Atlanta, Georgia, is one of the nation’s largest commercial banking organizations. The Company operates through an extensive distribution network primarily in Florida, Georgia, Maryland, Tennessee, Virginia and the District of Columbia and also serves customers in selected markets nationally. SunTrust’s primary businesses include deposit, credit, trust and investment services. Through various subsidiaries the Company provides credit cards, mortgage banking, insurance, brokerage, and capital market services. We understand that the purpose of this proposal is to reduce the time and effort required to comply with the certified statement process in order to provide regulatory burden relief. We are in agreement with your principle. We do have some comments regarding this new process. You specifically ask for comment on the e-mail notification as to the availability of the quarterly certified statement. We feel that this is a widely accepted industry practice to receive e-mail notification. Notification would serve as a reminder, making daily searches around notice time unnecessary. It would also ensure timely payments of assessment amounts. For back up purposes each institution should be allowed two or more employees who would have access to the site. We would suggest that each individual who has access also receive the e-mail notification. Thank you again for the opportunity to comment on this proposal. If you have any questions, please feel free to contact me at (404) 827-6622 or deborah.barnhart@suntrust.com Sincerely, Deborah Barnhart Vice President/Regulatory Reporting Manager SunTrust 303 Peachtree Street Atlanta, GA 30308
|