FDIC Federal Register Citations

Executive Secretary
ATTN: Comments/OES
Federal Deposit Insurance Corporation

From: Barbara J Coutley, Sr. Vice President/Secretary
Wauwatosa Savings Bank
7500 W State St
Wauwatosa, WI 53213

Comments on: Customer Identification Program referenced as follows
USA Patriot Act
FDIC, 12 CFR Part 326
Department of the Treasury, 31 CFD Part
103.121(b) (3)

In regard to Proposed Rules on Record Keeping 

The proposed rule regarding maintaining the information used to verify a customer's identity for 5 years after the account is closed will be cumbersome and difficult to track. We are a $1 billion dollar thrift in Southeastern Wisconsin. While we are technologically advanced for a financial our size, it will be very difficult to determine how long we need to keep each piece of information. We will probably end up keeping all of the information virtually forever, rather than make the mistake of deleting some too early I would suggest instead to base the record retention requirement on the account date was opened, rather than date closed.

1. We currently have existing record retention regulations for new account documentation. Adding the identification verification information to this group would be very simple even for an extended time.

2. Our assumption, based on our experience, is that problems with an individual occur very quickly in the relationship, if they are going to occur. We usually know by the end of one month if there is something "fishy" about that person or the information they provided.

3. All accounts opened in one month can easily be marked for destruction on a date in the future.

a. No matter what happens to each account in the future, they all have the open date in common.

b. If we open two accounts today, one may close next month & the other may close after 10 years making the destruction plan cumbersome.

Thank you for your consideration of this point.

Sincerely,

WAUWTOSA SAVINGS BANK
Barbara J Coutley