Federal Deposit
Insurance Corporation

I believe that obtaining valid and accurate identification from customers wishing to do business with any financial institution is extremely important, more so since the events of 9/11.

However, I have some apprehensions in regards to some of the proposed rules and wish to comment on them.

First, I do not think that a final rule and implementation date should be the same date. It is not possible to implement all the changes that may result from the final rule by that time - only 7 weeks away. I think the implementation date should be one year out from the final ruling.

Second, my financial institution uses very good due diligence in opening accounts for new customers. For non-US persons, we currently require a passport, an alien ID card, or a TIN if they already one. All accounts are monitored and audited through a departmental function, which includes OFAC, ChexSystems verification, and other internal methods.

There is no guidance in the proposal as to how one would verify and validate and authenticate the ID documentations. The methods we have in place seem to suffice; however, to make further obligations on the part of FIs would burden us perhaps unnecessarily. We need to have guidance from the FDIC in this area.

Third, we do not open any account for any individual without proper ID, a TIN number, and valid information. We verify the information by mailing a "thank you" card to the address used to open the account, to determine if it is valid. We do not open accounts with PO boxes, or mail box sites.

While my Bank firmly believes in thwarting terrorism and anti-money laundering efforts, we do not want to be so burdoned that the general public is punished by these rulings because of the minority.

Thank you for allowing time to respond.

Respectfully submitted,