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Below I have listed a few regulations that we feel are outdated,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
