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From: Marcia Freeberg Sent: Tuesday, September 03, 2002 4:09 PM To: Comments Subject: FIL-92-2002 August 22, 2002 Response to the Proposed Rule on Customer Identification Program: This FIL asks for comments regarding the CIP. I would like to see a clarification on the definition for "Account". Under 11. Section-by-Section Analysis, you define "Account". I am confused by the definition. The first paragraph tells me how Section 311 defines that term. The example you use includes both deposit accounts and credit accounts. The second paragraph tells me that this definition is not required for Section 326, but Treasury and the Agencies propose to keep the definitions consistent to avoid confusion. The next sentence talks only of Deposit Accounts and Transaction Account - no mention of credit accounts. So, do we include credit accounts in our CIP or exclude them? It would make sense to include them, but I think the final rule should be made more clear. Marcia J. Freeberg VP/Cashier Bank of Zumbrota
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Last Updated 09/06/2002 | regs@fdic.gov |