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FDIC Federal Register Citations

Commercial Bank

From: Debbie Gevedon []
Sent: Wednesday, May 04, 2005 11:45 AM
To: Comments
Subject: EGRPRA

To whom it may concern:

Thank you for the opportunity to your request for regulatory for burden relief, as published at 70 FR 5571. I am the Compliance Officer for Commercial Bank in West Liberty, KY. In addition to monitoring compliance in all aspects of our bank, I have also been designated to perform the day to day monitoring of BSA.

Our bank is a community bank. We strive to do the 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 1970's, it has become especially burdensome 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 is one of the most expensive and time consuming in our bank. Complex regulations lack clear and consistent guidance for bankers or examiners. We hear from enforcement agencies that information from the data we collect is useless in the form presented. Penalties are severe 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. Before any amendments will be successful, the data compilation must be re-designed in 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.

Money Service Business. While this crosses over to other areas of comment made in this letter, it is worthy of separate comment. Banks should not be expected to monitor the individual activities of each of its customers, absent suspicious activity or statutory/regulatory mandates. The recent examination efforts with regard to MSBs has proven that the response will be that financial institutions will no longer be willing to shoulder the potential risks associated with customers who are potentially MSBs. The burden of reporting should be placed on actual MSBs, not the bank.

USA Patriot Act. Many of the comments for BSA, above, are equally applicable to these requirements. There needs to be more clarification as to acceptable and appropriate identification standards. In addition, those standards must be consistent with the documentation and information available and verifiable in the various states.

Regulation D. The restrictions on transfers and the paying of interest on certain deposit account are archiac. These restrictions should be removed.

Again, thank you for this opportunity to comment.


Deborah Gevedon
Compliance Officer
Commercial Bank
West Liberty, KY

Last Updated 05/06/2005

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