Spiro State Bank
July 13, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
550 17th Street N.W.
Washington D.C. 20429
Dear Mr. Feldman:
This letter is a comment on the proposed changes to the assessment
certified statement rule (12 CFR Part 327) as discussed in FIL-74 2004. My
specific comments relate to the anticipation that the proposed changes would
reduce the time and effort required to comply with the certified statement
process, consistent with the FDIC's ongoing program under the Economic
Growth and Regulatory Paperwork Reduction Act.
I have processed the quarterly payment invoices for deposit insurance for
our bank since 1997. From my experience the current system works just fine
with very few complications. I can usually process the semiannual invoices
that must be signed and returned to the FDIC in around five minutes. The
other semiannual invoices, that do not have to be signed and returned, take
even less time.
I see no need to involve a personal computer, an internet service
provider, internet browser software, virus protection, firewall protection,
printers and toner, network hardware and software, the phone company, the
electric company and all of the, costs and breakdowns that can occur for
each of these items for a simple process that takes me less than five
minutes using an ink pen and a 37 cent stamp.
As I am sure you are aware this is not the only item the regulatory
agencies have moved to the internet. This massive transition to the internet
that the regulatory agencies are undertaking in an obscure attempt to reduce
regulatory burden and reduce regulatory costs is creating a larger
obstruction than is necessary. Additionally, any monetary savings achieved
through conducting this type of business through the internet is greatly
outweighed by the technology investments mentioned above in maintaining the
systems to retrieve, disseminate and respond to this correspondence.
If you have any questions or would like to discuss this matter further,
please contact me at 918-962-2453.
Sincerely,
Ty Barrett
Vice President
Spiro State Bank
Spiro, OK 74959
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