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FDIC Federal Register Citations Bank of Benton From: MICHELLE HARDIN [mailto:MICHELLEH@cfsvcs.com] Sent: Friday, April 29, 2005 10:57 AM To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov Subject: 70 FR 5571
To Whom It May Concern: Thank you for the opportunity to your request for regulatory burden relief, as published at 70 FR 5571. I am BSA Officer/Deposit Compliance Officer for the Bank of Benton in Benton, KY. BSA has become a full time job for this community bank. We strive to do the very best job possible to serve the community and its members. Often that attempt to serve is hampered by undue and unnecessary regulatory burden. Although that has been the case, increasingly, since the 1970s, it has become unmanageable since the September 11 terrorist attacks. While we understand the need to secure our country and its financial infrastructure, I question whether the regulations, as implemented and enforced are accomplishing that goal. Specifically, I am concerned about the following: ·
Bank
Secrecy Act. Compliance with this Act and its regulations in, without a
doubt one of the most expensive and time consuming in the bank. That is
compounded by complex regulations the lack of clear and consistent guidance
for examiners; the apparent ineffectiveness of the data collected; and,
severe penalties for unintentional or misunderstood noncompliance. The
regulations need to be streamlined and clarified. Examiners should look to
advise and assist institutions with compliance rather than punish. But,
before any amendments will be successful, the data compilation must also be
re-designed tin such a way, and tested, to ensure that law enforcement will
and can utilize it. Otherwise, the regulatory burden cannot be justified
for the bank or the consumer. Again, thank you for this opportunity to comment.
Michelle Hardin, |
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Last Updated 05/02/2005 | Regs@fdic.gov |