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From: Linda Hoth [mailto:lhoth@RoyalBank-usa.com]
Sent: Tuesday, May 03, 2005 3:00 PM
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:
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.
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
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.
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.
|Last Updated 05/04/2005||Regs@fdic.gov|