SUNTRUST
July 21, 2004
Robert E. Feldman
Executive Secretary, Federal Deposit
Insurance Corporation
500 17th Street, N. W.
Washington, DC 20429
Via e-mail: regs.comments@FDIC.gov
Reference: Federal Register/Vol. 69, No. 110
Proposed Amendment to 12 CFR 327.2
To Modernize and Simplify the Certified Statement Process
Dear Mr. Feldman:
SunTrust Banks, Inc. (SunTrust) appreciates the opportunity to comment on
the proposal to obtain
certified statements on the Internet via the FDIC’s transaction-based
e-business web site. SunTrust
Banks, Inc., headquartered in Atlanta, Georgia, is one of the nation’s
largest commercial banking
organizations. The Company operates through an extensive distribution
network primarily in Florida,
Georgia, Maryland, Tennessee, Virginia and the District of Columbia and also
serves customers in
selected markets nationally. SunTrust’s primary businesses include deposit,
credit, trust and
investment services. Through various subsidiaries the Company provides
credit cards, mortgage
banking, insurance, brokerage, and capital market services.
We understand that the purpose of this proposal is to reduce the time and
effort required to comply
with the certified statement process in order to provide regulatory burden
relief. We are in agreement
with your principle. We do have some comments regarding this new process.
You specifically ask for comment on the e-mail notification as to the
availability of the quarterly
certified statement. We feel that this is a widely accepted industry
practice to receive e-mail
notification. Notification would serve as a reminder, making daily searches
around notice time
unnecessary. It would also ensure timely payments of assessment amounts.
For back up purposes each institution should be allowed two or more
employees who would have
access to the site. We would suggest that each individual who has access
also receive the e-mail
notification.
Thank you again for the opportunity to comment on this proposal. If you
have any questions, please
feel free to contact me at (404) 827-6622 or
deborah.barnhart@suntrust.com
Sincerely,
Deborah Barnhart
Vice President/Regulatory Reporting Manager
SunTrust
303 Peachtree Street
Atlanta, GA 30308
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