FDIC Federal Register Citations

FDIC

Attention: Section 326 Bank Rule Comments

Union Bank & Trust Company is the Program Manager of the College Savings Plan of Nebraska, a qualified tuition program pursuant to Section 529 of the U.S. Internal Revenue Code. The program has been operational since January 1, 2001. Although a non-deposit, non-FDIC insured product, the College Savings Plan of Nebraska will be subject to the regulations of the US Patriot Act as part of Union Bank & Trust Company, a Nebraska-based financial institution.

Below we list our comments for consideration regarding the US Patriot Act:

The conclusion reached in the proposal that the new requirements have a minimal effect on small institutions is not true in our case. The regulations will greatly increase the amount of identification we must obtain, including increased cost.

Due to the nature of the College Savings Plan of Nebraska and its low risk assessment, it is recommended that the application completed fully, including physical address of residency if different than the mailing address, be evidence enough that we identified our customer.

We thank you for the opportunity to comment on the proposed US Patriot Act.

Respectfully Submitted

Donna R. Crownover
Client Service Officer
College Savings Plan of Nebraska

COLLEGE SAVINGS PLAN OF NEBRASKA