FDIC Federal Register Citations

United Bank of El Paso del Norte

From: Kim McGlone
Sent: Thursday, July 29, 2004 11:29 AM
To: 'regs.comments@federalreserve.gov'; Comments; 'regs.comments@occ.treas.gov'; 'regs.comments@ots.treas.gov'
Subject: EGRPRA

Comments from:

Jim McVay
EVP for Operations
United Bank of El Paso del Norte

OK. I read several of the comments/recommendations and they are as
involved as the regulations themselves. I think that to get to the point
that all bankers would like to get to would require drastic action. I
propose something similar to the sunset approach, except my proposal is that
when a regulation pertaining to disclosure requirements, either on the
deposit side or the lending side, is up for ammendment, every member of that
committee should be required to read a random sampling of disclosure
statements from banks that have had the examiners pass on their disclosures.
Then each member of that committee should be required, after one reading, to
pass a written test tailored to each disclosure. The results of the tests
should be published. Then, the applicable regulation should reviewed by the
committee with an eye toward making the requirements on the banks more
reasonable with the resulting required disclosure something that the normal
bank customer can understand and appreciate. If they can't accomplish that
within a reasonable deadline, then the regulation and disclosure should be
repealed. To set the tone for the above process, I think all legislators
that are on banking committees should initially have to read the disclosures
banks are required to give to all customers who merely open a simple
checking account. An abbreviated test would be required just to make sure
each person did in fact read the disclosure. The purpose of this exercise
would mainly be to remind each of the legislators of the 11th Commandment,
" Thou shalt not take thyself too seriously."
I tried to send these comments through the IBAT Forums website but I
am not registered and my input was denied. However, my comments are serious
and are not intended to be humorous or taken as tongue in cheek. Please
pass them on. Thanks.