FDIC Federal Register Citations

EFS Bank

From: Jerry Gosse [mailto:jgosse@efsbank.com]
Sent: Friday, October 15, 2004 3:36 PM
To: Best, Valerie
Subject: EGRPRA Webmaster

I suggest that you consider having someone (other than a lawyer) re-write Regulation Z from top to bottom. What began as a useful tool designed make consumers aware of the cost of credit (and be able to shop and compare costs) has evolved into an extremely lengthy, very technically complex regulation which is not only burdensome for banks to comply with, but (I believe) very difficult for consumers to understand. The revised regulation should not be longer that five pages with "bullet points" to highlight the purpose of the regulation and "user friendly" for easy comprehension by consumers and better compliance by bankers.

The purpose of this regulation was not to make it so difficult that one needs a "Philadelphia lawer" to read it and comply with it, but to provide understandable information to consumers about their loans.

The reg needs to be re-written starting with the purpose and intent of the regulation in the first place. I suggest that the group that writes it include bankers themselves or personnel with banking experience and someone that is efficient at editing and simplifying the subject matter to keep it short enough so that anyone can read it without numerous references to other sections of it or other regulations.

I truly do not expect this to happen (re-writing the reg), but I needed to tell it like I see it since you are asking for input.

Yours truly,

Jerry Gosse
Compliance Officer (and former regulator for 28 years prior to retirement)
EFS Bank