FDIC Federal Register Citations

My comment relates to the issue that Congress intended the verification procedures in the act to make use of information currently obtained by most financial institutions in the account opening process. The definition of a "customer" in the proposed rule includes an individual with signing authority over a corporate account. This would require the collection, verification and record keeping of additional information for our bank in that we currently do not follow these procedures for every person signing on a corporate account. The retention requirements for information used to verify identity poses another problem for us. It is not possible to record all of the information required to be collected under this regulation on our deposit account signature cards or loan documents, which are imaged on a network for all employees to view. My understanding is that we will be required to keep a copy of the social security card, driver's license, etc. used to verify the identity. Our concern is how can we retain this information and maintain it in a way that is accessible for employees without being criticized under anti discrimination laws or regulations, such as Equal Credit Opportunity. Our bank currently has eleven offices and had total assets of $243 million as of June 30, 2002.

Debbie Young, Compliance Officer
Northeast Georgia Bank
12461 Augusta Road
Lavonia, Georgia 30553
FDIC Certificate Number 15771
dyoung@northeastgabank.com