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FDIC Federal Register Citations

Bank of Prescott

From: Jim Franks
Sent: Tuesday, July 18, 2006 12:37 PM
To: Comments

Subject: Identity Theft Red Flags and Address Discrepancies Under FACTA - 12 CFR Parts 334 and 364

RE: Proposed rule for Identity Theft “red flags”

To whom it may concern:

I would like to enter my strong objection to the recently announced “Notice of Proposed Rule Making” concerning the requirement that our bank have a policy as well as procedures to detect patterns and practices of identity theft and to mitigate such instances if so discovered, even though these instances of potential identity theft were not caused by our bank. Common sense is still used in our bank!! My first thought, after reading your 155-page “Notice” document, was “You’ve got to be kidding me!”

While our bank, as well as I, is concerned about a person’s theft of identity, I strongly disagree that the Federal government should once again make my bank the “policeman of the world.” We do enough of that already. Our bank is not a law enforcement agency. Identity theft can occur through no fault of a person, or it can be completely that person’s fault because of gross negligence or incompetence. Either way, it is not the fault of our bank. Therefore, it begs the question as to why my bank should foot the bill and have to implement procedures to detect such things. Our community has a local and state police force. One can argue one way or the other as to their suitability for handling such crimes, but the fact remains that it is they, the law enforcement community, that is charged with this responsibility – not a financial institution.

Today our bank goes to great strides to protect our customers’ information, and we would suffer greatly (financial and otherwise) should we violate that trust, even though the violation would be unintentional. Therefore, it certainly behooves our employees to do all that is practical to protect customer information, and we do. Now, however, you are asking our bank to go yet another step, one that is neither required nor necessary. You are only adding more paperwork, more policies and procedures. The more policies you make us write, the less we can serve our customers, the less we can do “real” banking. It seems to never stop; some bureaucrat who has no dealings with the public, sitting in a chair in some government office, decides to make banks write more policies. It just never ceases to amaze me.

Sincerely,

Jim Franks

Bank of Prescott

 


Last Updated 05/30/2006 Regs@fdic.gov

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