From: Diane Foltz
Sent: Tuesday, September 14, 2004 12:59 PM
To: Comments
Subject: EGRPRA Burden Reduction
Dear Mr. Feldman:
I appreciate the opportunity to comment on the efforts to reduce
regulatory burden in our industry. I represent a $437 million community
bank with seven offices in our county. Please consider the following
in regards to your request:
Regulation H: We feel that getting the credit disclosure signed
within three days is particularly burdensome. Many of our applications
are taken over the phone and credit insurance is solicited at that
time. Disclosures are sent within three days but are rarely signed
and returned, especially if the loan is not originated. It is difficult
and costly to send letters and make calls in an effort to get the
disclosure returned. This disclosure should be eliminated and replaced
with a disclosure signed at closing confirming the purchase of the
insurance. However, even that seems to duplicate the requirements
Regulation Z sets forth for the purchase of optional insurance. It
does not feel, with today's requirements, that we are providing service
to our customers when we require them to sign three disclosures (credit,
insurance and Reg Z confirmation) just to confirm the purchase of
insurance in connection with a loan on top of the forms required
by the insurance company.
Regulation P: As stated in several other comment letters, the annual
notice requirements for the privacy notices are very costly to our
community banks, especially when the notice has not changed from
the previous mailing. Giving consumers a notice at account opening
and any time there is a change should be sufficient. Please remember
that institutions have this notice on their website for consumers
to review at their convenience in the event they need to. The annual
mailing requirement could also be replaced with a lobby notice requirement.
Again, with the website notice and a lobby notice, those interested
would have multiple ways to access the notice while providing institutions
with a substantial cost savings. We also oppose any amendments to
the content or form of the notice that would make the requirements
under the regulation more burdensome.
Safeguarding of Customer
Information: Several areas here are burdensome and costly for community
banks to comply with. Risk analysis, documentation
requirements and vendor due diligence requirements are good examples.
We understand that there is no "one size fits all" answer
here, however the guidelines provide very little assistance in these
areas leaving banks scrambling. Commentary and/or clarity of intent
would be helpful here.
Regulation E: The quarterly statement requirement for savings accounts
that have EFT capabilities but no EFT activity is a costly burden.
We ask that you consider allowing savings account statements which
have no EFT activity to be moved to a semi-annual or annual statement
cycle.
Thank you for allowing us to comment on this topic. We hope to see
action taken towards reducing regulatory burdens in our industry
in the near future.
Sincerely,
Diane M. Foltz
Farmers State Bank
Compliance Officer
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