FDIC Federal Register Citations

Executive Secretary
Federal Deposit Insurance Corporation 
550 17th Street., NW
Washington, DC 20429

Attn: Comments/OES

Dear Mr./Ms. Secretary:

As a member of Senior Management of United Nebraska Bank, I would like to comment on the proposed USA Patriot Act of 2001. After reading about the regulation and visiting with other members of the banking industry, I have some concerns about the requirements of the Act and our ability to put practical procedures in place to assure our bank's compliance.

1. I feel that the regulation should not apply to individuals "seeking" to open an account. Financial institutions should not be required to maintain records in situations where an individual is not actually receiving financial institution services. Without a relationship, there is not an easy way to obtain the information or to maintain these records.

2. Extending coverage of this regulation to all new signatories on an account is extremely problematic. In cases where multiple signatories to an account are large in number, verification of all of those individuals will be extremely costly and time-consuming. This requirement places an undo amount of risk on the bank from both a monitoring and recordkeeping standpoint.

3. The proposal for a 5-year record retention period is excessive. This is well beyond other 2-year recordkeeping limits for other similar customer information regulations.

4. The proposal to require retaining copies of picture identification (typically driver's licenses) is impractical and burdensome. This information cannot be kept in lending files, or the bank would be in violation of anti-discriminatory regulations. As a bank we would have to find an alternative filing system at an unnecessary cost to the bank. This is also unnecessary in cases where we have known our customer for many years. We recommend simple procedures where we review identification as part of establishing a relationship with an individual not known to the bank.

We appreciate your time in reading this comment and ask that you first consider extending the implementation date at least 1 year from the original October 2002. This short time from the comment period of September 6, 2002 to October 25, 2002 will find most financial institutions not in compliance. There are many banks with similar concerns, please take time to read the comments on this Act that you receive.

Sincerely,

David L. Christanson
President/CEO and Director