FDIC Federal Register Citations

Subject: Customer Identification Programs for Banks

Garden Plain State Bank is a $50 million bank located in Wichita, Kansas.
The comments I have regarding CIPs for banks do not specifically fit the
eight questions targeted in the Federal Register, so I will use a free
format. I hope you will strongly consider my concerns and suggestions,
because I believe they represent the concerns of many smaller community
banks across the nation.

I understand the importance and reasoning behind the push to implement the
CIP. My main concern, however, is with our long-standing customers, usually
elderly, who will not understand the need. We have many customers that have
banked with us for over 30 years who will be appalled that we ask for a form
of identification. I would like to see some type of exemption for existing
customers.

The Federal Register states that the CIP must contain risk-based identity
verification procedures and lists an example that "a bank need not verify
the identifying information of an existing customer seeking to open a new
account, or who becomes a signatory on an account, if the bank (1)
previously verified the customer's identity in accordance with procedures
consistent with this regulation, and (2) continues to have a reasonable
belief that it knows the true identity of the customer." I strongly
encourage you to incorporate this into the final regulation. As mentioned
above, I believe we will have many customers who are outraged that we need
identifying information, let alone if we have to obtain it from them each
time they open a new account.

The means in which to identify a customer is also a concern. In the past we
have been told not to copy drivers licenses and put them in account files
because of Regulation B issues. We are now being told that we must maintain
some form of identifying information, an unexpired drivers license or
identification card issued by the state being the most logical form. I
would like the regulation to specifically state that this form of
identification is acceptable and will not be in violation of Regulation B
unless the information on the identifying information is used to
discriminate.

Five years after closing is a very long time to maintain some types of
records. I would like to see the record keeping requirement set to 25
months to coincide with the amount of time bank's are required to keep
application and adverse action notices in accordance with Regulation B.

I also would like to see the government agencies issue software for
comparing customers to government lists. A web-site where the bank could
type in new customer names for comparison would also be welcome. Currently,
the purchase of software has been cost prohibitive for our bank. This
regulation will force us to purchase some type of software, and will force
us to incur additional monetary costs as well as personnel costs to install,
maintain, and use the software.

And finally, I hope that once the final regulation is issued, banks will be
given sufficient time to implement the CIP. Time to read and understand the
regulation, write policies, obtain Board approval, implement daily
procedures, and train personnel is very hard to designate in a small
institution where all employees wear many hats.

Again, I hope you take these comments and suggestions to heart when deciding
on a final regulation and understand the burden that such regulations place
on small community banks.

Deneen Fayette
Senior Vice President
Garden Plain State Bank
10526 W. Maple
Wichita, KS 67209-4012
(316) 721-1500