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FDIC Federal Register Citations

CHEROKEE STATE BANK

FDIC
4300 S Lakeport STE 104
Sioux City IA 51106

RE: Recommendations Sought to Reduce Regulatory Burden

To Whom It May Concern:

Below I have listed a few regulations that we feel are outdated, unnecessary, and burdensome.

1. Right of rescission has outlived its usefulness. Customers are usually frustrated with this process, since in many cases the customer has already made a commitment to a home improvement project or may already have purchased the vehicle. When the money has already been spent or committed, they do not cherish the idea of waiting an additional three days before they can get their loan proceeds.

2. Appraisal requirements are too stringent and need to be changed with the increased cost of housing, land and real estate in general. The appraisal requirement could be at least doubled from the present $250,000 to $500,000. Our bank has staff that can do a very adequate Job of assessing property valuation. Increasing the amount to $500,000 would also reduce the borrower's cost in a real estate transaction.

3. Need to change the requirement to send privacy notices annually. This regulation is not necessary. Customers are given a privacy notice when they open an account. As long as the bank does not make any changes to their privacy policy, the requirement to send an annual notice is overkill. I fear most of these notices don't even get a second look by the customer, but instead windup in their garbage.

4. Biennial renewal of exempt persons or businesses is an unnecessary burdensome regulation that needs changing. Once a person or business has gone thru the exemption process, there should be no need for them to go thru the renewal process. Financial institutions should only have to terminate or revoke the exemption if they cease to operate as a business or no longer have a banking relationship with the bank that originally exempted them.

5. The HUD form should exclude the columns disclosing the seller's expenses. The closing agent discloses this to the seller. It should not be our responsibility and it is redundant.

Sincerely,

Ivan Wiersema
V.P. & Compliance Officer
Cherokee State Bank
Cherokee, IA


Last Updated 04/05/2004 regs@fdic.gov

Last Updated: August 4, 2024