From: David Young [mailto:dyoung@citizensada.com]
Sent: Monday, July 12, 2004 12:12 PM
To: Comments
Subject: Part 327 - Certified Statements
Sirs:
After having read the proposed rule, I have the following comments:
1. The paperwork burden being reduced will be greatly appreciated. I
believe the steps being proposed are fully justified, and will assist
all internet ready institutions in the fulfillment of this obligation.
I am concerned about the possibility of this being seen as an unfunded
mandate to those institutions that do not have internet access. Quite
possibly, this program should initially be introduced as a bank determined
option, rather than a mandate. I believe most banks will accept this
form of delivery as their preferred option.
2. I believe that as a condition of the banks’ accepting this
report delivery method, the FDIC should be obligated to deliver to
the primary
and secondary contacts at each institution, an e-mail notifying them
of the availability of the report, and strongly suggesting that the
institution retrieve a copy of the document for verification of accuracy.
If this
program is set up as an option for the institution, you may want to
include a tracking system to determine those banks that have not pulled
the report,
and generate either a reminder e-mail, or send out a paper copy.
Thank you for considering my opinions on this.
David Young,
Vice President,
Citizens Bank of Ada