|
|
|
|
|
Home > Regulation & Examinations >
Laws & Regulations > FDIC
Federal Register Citations |
|
|
|
|||
|
FDIC Federal Register Citations From: Linda Hoth [mailto:lhoth@RoyalBank-usa.com] Sent: Tuesday, May 03, 2005 3:00 PM To: Comments Subject: EGRPRA burden reduction comment Our bank consists of 11 offices serving the needs of our Wisconsin communities with populations ranging from slightly over 400, to not quite 1,600 people. Our ability to serve our customers is made increasingly more difficult and confusing by the incredible amount of regulatory requirements passed over the years, especially since 9/11. In response to the Agencies' request for recommendations on how to reduce regulatory burden, we offer the following suggestions: CTRs Increase the CTR reporting threshold from $10,000 to $25,000 and automatically adjust for inflation every five (5) years. The current dollar limit is way too low and results in filings that appear to be of questionable value to law enforcement. Monetary Instrument Logs Increase the dollar threshold from $3,000 to $15,000 and automatically adjust for inflation every five (5) years. Exempt Customers Eliminate the requirement to file a Designation of Exempt Person for transactions between federally-insured institutions. Shorten the waiting period from 12 months to six. Unless we're dealing with a seasonal business, the deposit habits can usually be determined in that time period. In situations where an existing exempt business changes financial institutions does the government really want the new financial institution to submit a year's worth of CTRs? Or, if there is a change in ownership, is it really helpful to have the new owners of an existing exempt business re-establish the deposit history for 12 months? Also, eliminate the biennial filing requirement for exempt customers. What purpose does this serve? We are already required to actively monitor our exempt customers and determine on an annual basis that they still qualify to be exempt, as well as monitor them for suspicious activity. SARs The regulators, FinCEN and the various law enforcement agencies should work together to determine the appropriate dollar thresholds and specific types of suspicious activity for the required filing of this document. Are SARs triggered by the $5,000 dollar threshold where a suspect can be identified, or that involve potential money laundering or violations of the BSA, of value to law enforcement? Even insider abuse involving any amount should be reviewed and a specific dollar threshold established. With staff and budget resources spread thin, at what point will law enforcement even consider investigating suspicious activity? Thank you for this opportunity to comment. Kim Anderson VP/Compliance Officer |
|
|
Last Updated 05/04/2005 | Regs@fdic.gov |
