FDIC Federal Register Citations

From: Ratna Ray [mailto:rray@rockvillebank.com]
Sent: Friday, April 16, 2004 2:35 PM
To: Comments
Subject: EGRPRA burden reduction comments

GLBA- The act as it states puts tremendous amount of work on bank's part to be in compliance. Not only that, it requires enormous amount of paper work as supporting documents for verification by regulatory examiners.

REG E- This Regulation requires too many correspondence with customers to be in compliance, specially on Debit card issues while card holder has no
liability for unauthorized transactions. Merchants also have very little
liability. The way the REG E is formulated now, the complete financial burden is on the bank as merchants do not verify the cardholder's identity. Card holders do not report promptly the loss of the card. The regulation should be revised to have the bank liable for only within 24 hours preceding the notification of the last card.

REG D- Presently the Regulation does not allow more than six transactions
total of six preauthorized and electronic during 30 day period on a Statement Savings Account. This regulation was enacted long before Internet banking was popular. Now with more and more customers using electronic banking, this limitation is a burden on the bank as it requires monitoring, documenting, correspondence with customers and take action as necessary. Moreover, it is an impediment to the utilization of electronic banking which we all try to promote. This limitation should be removed or relaxed to a larger number of transactions