Sevier County
Bank
From: James Temple
[mailto:jat@norvellpoe.com]
Sent: Tuesday, April 20, 2004 7:00 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
Vice Chairman
John Reich,
Federal Deposit Insurance Corporation
Washington, D.
C.
IN RE: Economic
Growth and Regulatory Paperwork Reduction Act of 1996
(EGRPRA)
Dear FDIC:
I appreciate
the opportunity to comment on the growing amount of Federal
regulations.
The Bank is expected
to be still and compliant while we are suffocated by
ever increasing regulation, we are also expected to train our employees, for
free, so they can police our customers – for whatever happens to be the
focus of the moment: illegal aliens, drug money, un-reported income, or
confiscating counterfeit currency from usually unsuspecting individual or
small business owner.
Over the years the number, complexity and expense of all these regulations
have increased far beyond any other banking costs. I also suspect (but don’
t have the in-house resources to waste on proving) that commercial banking
is the most disparately regulated line of business. Often we have been
penalized during an examination due to differing views or opinions, of the
individual examiner. What was acceptable during the previous exam is not
now, and there is no recourse to this “difference of opinion”.
Other points
of thought:
1. Admit that
not all banks, credit unions, S&Ls, etc. are not the same,
and
change all laws accordingly. It makes no sense, either logically,
economically or socially that Sevier County Bank with total assets of less
than $300 million should have to comply to the same regulations that a
billion-dollar plus bank or credit unions does.
2. If Congress
must make rules, they must be applied consistently and fairly
to all: banks, S&Ls, credit unions, small loan companies, non-bank banks,
and so on. If a “business” wants to have any sort of federally
insured
checking accounts or make loans on a regular basis, it should have to have
FDIC approval and examinations and follow CRA, Reg. Z, RESPA, etc. etc.
3. IF Congress
must make rules, they must either fund them out of their own
(IRS) pocket or reimburse the businesses (banks in this case) and includes
paying to print, train, and PROTECT those who must enforce or implement
their rules. The large currency transactions (Bank Secrecy Act) and all the
free reporting to the IRS and FinCEN come to mind.
4. Allow the
individual States to compete by not over-riding their rules and
thus usurping their sovereignty. The dual banking system is the wonder of
the world and yet the Comptroller, the SEC and others seek to roll us all
into one. The exceptions would be national security and monetary policy.
Thanks and we
look forward to hearing from you on this.
Respectfully
yours,
James Temple,
Jr., PE
Professional Engineer & Outside Director of Sevier County Bank
Norvell & Poe,
Engineers LLC
Registered Engineers & Land Surveyors
635 Wall Street
Sevierville, TN 37862
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