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FDIC Federal Register Citations

Rockland Trust Company

May 9, 2005
Robert E Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Mr. Feldman:

Rockland Trust appreciates the opportunity to comment on the proposed regulations referenced above.  Rockland Trust is the sole banking subsidiary of Independent Bank Corp., which is one of the largest independent commercial bank headquartered in Massachusetts. Rockland Trust Company has 50 retail branches, eight commercial lending centers and three investment management offices located in Southeastern Massachusetts.  The Company’s primary business lines are commercial lending, retail banking and investment management.

As a banking entity with nearly $3 Billion is assets our primary cause for concern is the money laundering regulations and their burdensome nature.  We believe that certain aspects of the regulatory requirements are outdated and do not meet their intended purpose.  We firmly believe that banks should focus their assets on identifying suspicious activity, and not spend time and resources on CTR reporting and monetary instrument reporting. 

CTR Reporting

We believe that CTR reporting should be eliminated because it does not meet the “high degree of usefulness” standard required in the Bank Secrecy Act.  Many of the aspects thought to be beneficial in CTR reporting have been replaced by CIP programs and stronger suspicious activity reporting controls.  If eliminating the reporting is not an option, then amending the dollar requirements should be a prerequisite to maintaining the CTR system.  Using the same dollar thresholds to file a CTR as when the law was issued makes the reports of little or no value. 

Monetary Instrument Reporting

The customer identification & verification changes that became effective in the USA Patriot Act seem to make the monetary instrument log recordkeeping issues redundant. 

The resources saved on altering these two requirements may be reallocated to better identify, research and report true suspicious activity. 

We appreciate the opportunity to comment on this matter.

Christopher Burgess
Vice President - Director of Compliance & Bank Secrecy Act Officer
Rockland Trust Company
288 Union Street
Rockland, MA 02370

Last Updated 05/12/2005

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