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FDIC Federal Register Citations CALVIN B. TAYLOR BANKING CO. April 12, 2005 Mr. Robert E. Feldman, Executive Secretary Re: Reducing Regulatory Burden Money Laundering, Safety and Soundness and Securities Rules Dear Mr. Feldman: We are pleased to submit comments on reducing regulatory burden relating to Money Laundering, Safety and Soundness, and Securities Rules. The regulations enacted pursuant to the Bank Secrecy Act and anti-money laundering are our most burdensome regulations. Below are our recommendations to alleviate the burden without impacting the intent of the regulations: Money Laundering - Increase the threshold for transactions requiring CTRs from $10,000 to $25,000. The $10,000 threshold has not been changed since it was established in 1979. Back then cash transactions over $10,000 were an infrequent event, now it is common to process these types of transaction and it causes a burden due to the large number of CTRs that must be filed. Money Laundering - Eliminate the biennial renewal of Phase II exemptions. Permit the initial exemption to continue until the bank determines that the customers attributes no longer qualify for exempt treatment. In addition, because the annual review of eligibility status must be done, it appears to be redundant to require the bank to file a biennial renewal document.
Money Laundering - Reduce the eligibility period to
qualify for exempt status. If a new customer has conducted frequent
currency transactions during the initial 6 months reduce the time a
customer may be eligible for exempt status from 12 to 6 months. We appreciate the opportunity to participate in this endeavor to reduce outdated, unnecessary and unduly burdensome regulatory requirements. Sincerely, CALVIN B. TAYLOR BANKING CO. |
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Last Updated 04/13/2005 | Regs@fdic.gov |