FDIC Federal Register Citations

I would like to make the following comments regarding the Proposed Rule under Section 326 of the USA Patriot Act on behalf of High Point Bank and Trust Company.

1. Coverage - While 326 applies to all financial institutions, the proposed rule does not cover "money services businesses" or several other businesses listed under the Bank Secrecy Act. High Point Bank and Trust Company opposes the lack of coverage for money transmitters.

2. Customer - The proposed definition defines "customer" as any person seeking to open an account and any "signatory" on an account. The regulations should not require recordkeeping for situations where an individual does not actually receive bank services. The final rule should exclude coverage for those simply seeking information or that are denied requested services.

3. Signatory - The coverage of all new signatories on an account is an extreme problem. Arguably guarantors on loans could be covered under the current definition. In addition, the verification and recordkeeping in cases where there are numerous (and frequently changing) signatories will be extremely expensive and labor intensive. We believe thee is a need for a "risk-based" response to the issue of signatories.

4. Copying of driver's licenses and other U.S. documents - As our bank has discussed the proposal, we believe this requirement will necessitate the maintenance of a central file on customers to avoid the appearance of a Regulation B violation. The cost of copying this information and maintaining such a file will be burdensome. We recommend that instead of requiring the copying and retention of documents, that the account application or signature card be allowed to be used to note the document used to verify identity.

Sincerely,
Kim Parker, Compliance Officer
High Point Bank and Trust Company
300 N. Main Street
High Point, North Carolina 27260