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Bank of the Bluegrass & Trust Co. From: Ellen Mills [mailto:emills@bankofthebluegrass.com] Sent: Thursday, April 28, 2005 3:58 PM To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov Subject: EGRPRA
Thank you for the opportunity to respond
regarding regulatory burden relief.
My name is Ellen Jett Mills. I am Compliance
Officer, OFAC Officer, Privacy Manager, BSA Officer and Secretary of the
Board of Directors of Bank of the Bluegrass & Trust Co. in Lexington,
Kentucky. I have just been through a BSA Examination, and I believe I can
offer some suggestions on the burden of Bank Secrecy/anti-money laundering
regulations facing community banks.
Despite very public statements that bank
regulators are not operating with a zero tolerance policy and despite
claims that regulators are not treating all institutions like mega banks,
the examiners in the field have stated that they do not have the leeway to
operate except under a zero tolerance environment. This environment can
not possibly take into consideration the less formalized risk assessments
of community banks.
Requiring Banks to continuing filing for
exempt status for transactions between banks is an unnecessary burden. If
currency transactions with Federal Reserve Institutions are already
exempt, why not exempt currency transactions between all FDIC insured
institutions? Treating the exemption/revocation of exemption of banks as
a violation merely raises banks regulatory burden, along with the number
of violations cited. There can be no added benefit of these extra forms
and the citing of these violations.
Requiring CTRs to be filed within 15 days is
an unnecessary burden when the forms are not being reviewed immediately
upon government receipt. A 30 day limit would not substantially increase
the time the government must wait for the information, but it would give
community banks with limited staffs the ability to comply with the law
with less violations.
13 Million CTRs filed a year is overwhelming
and so the bulk these forms are not reviewed by government officials.
Increasing the thresh hold amount for filing a CTR would reduce both the
burden and number of CTRs. Increasing the $10,000 threshhold to $15,000
would decrease our CTR filings by an estimated 75% and would not
substantially increase the likelihood of someone using our facility in an
attempt to launder money.
BSA/Anti-money Laundering procedures are
forcing banks to serve as uncompensated law enforcement. Given this
reality, it would be helpful if community banks weren't hammered for good
faith efforts to comply with the laws.
Sincerely,
Ellen Jett Mills
Bank of the Bluegrass & Trust Co.
101 East High Street
Lexington, KY 40507
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Last Updated 04/29/2005 | regs@fdic.gov |