FDIC Federal Register Citations

Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Attn: Comments/OES

Dear Sir,

In regards to proposed rules for section 326 of the USA PATRIOT Act of 2001 I have the following comments. First please make sure there is an adequate path through the regulation for small institutions to follow. We have 5 full time employees and to add a time consuming process to our compliance load is ultimately counterproductive in my opinion.

Secondly the records retention period of 5 years is not consistent with the 2 year requirements set forth in many other regulations. It would be most helpful to us to keep the records retention bar at the same "height" of two years.

Third on my list is I ask that clarification of the terms of the proposed rule covering those "seeking to open account(s)" be made in such a way so that we only have to collect this information on individuals actually asking to complete the paperwork to open an account and does not include those shopping for terms on an account. I am concerned that the rule as written will have us verifying identity on shoppers before we can answer questions on the terms of accounts. This would be unacceptable to the public and a barrier to competition.

Fourth is there going to be a web site or some other mechanism available to verify Social Security Numbers? We will need a method of doing this that is easy and fast to use to make this policy directive effective.

And my last topic for comment is that keeping copies of drivers license's is not going to provide as certain a system as may be hoped. First the standards to get a license in some states is something easily complied with. Illegal aliens, I am told by our local sheriffs office, often have a valid drivers license from other states. In addition I think this proposed requirement will be burdensome over time and the quality of copies of picture ID is highly variable.

Thank you for your time and attention to this matter. If you have any questions please let me know.
Respectfully,

Kent M. Franzen, Sr.VP 
State Bank of Trenton
PO Box 338
Trenton NE 69044