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FDIC Federal Register Citations |
August 30, 2002
VIA FASCIMILE AND ELECTRONIC MAIL RE: Proposed Regulation 12 CFR Part 326: Customer Identification Programs for Banks, Savings Associations and Credit Unions To Whom It May Concern: First Morris Bank and Trust (FMBT) is pleased to have the opportunity to offer comments on the recently issued rules proposal relating to Section 326 of the USA Patriot Act (Customer Identification Program). FMBT is a local community bank with eight branches in Morris County, New Jersey. Our asset size is $338 Million and we currently employ one hundred fourteen people. Since 1969, we have been providing banking and investment services to individuals and businesses throughout the county. With regard to the proposed rules, we would like to offer the following comments and requests for clarification: 1. Section 103.121 - Definition of Customer The first part of this section proposes to define a 'customer' as
"any person seeking to open a new account". We feel that this
definition is too broad, requiring the same identification requirements
for those persons with whom we actually establish a relationship, as well
as those who potentially seek to establish a relationship (for example: a
loan applicant). As outlined in subsequent sections of the proposal, the
identification requirements include photocopying driver's licenses. We are
of the opinion that requesting identification from individuals who have
not yet initiated an account or loan relationship is burdensome due to the
record retention involved. 2. Section 103.121(b)(3) - Recordkeeping Lastly, as stated in the USA Patriot Act, compliance with the Section 326 rules will be mandatory October 26, 2002. The proposal was only issued on July 23, 2002 and is open for a 45-day comment period. This only gives the agencies approximately six weeks to review the comments and issue a final regulation, giving banks inadequate time to write and implement effective procedures to meet the requirements. We request that the agencies consider a more reasonable effective date sometime in the first quarter of 2003. Thank you for your consideration and review of our comments. Very truly yours, Lisa Nienaber Jane Block First Morris Bank and Trust cc: B. Giovinazzi, President and CEO, FMBT |
Last Updated 08/30/2002 | regs@fdic.gov |