From: Kim Parker
Sent: Friday, September 06, 2002 5:15 PM
To: Comments
Subject: Proposed Rule under Section 326 of the USA Patriot Act - Customer Identification
Program
Executive Secretary
Attention: Comments/OES,
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429 I would like to make the following comments regarding the Proposed
Rule under Section 326 of the USA Patriot Act on behalf of High Point Bank and Trust
Company.
1. Coverage - While 326 applies to all financial institutions, the
proposed rule does not cover "money services businesses" or several other
businesses listed under the Bank Secrecy Act. High Point Bank and Trust Company opposes
the lack of coverage for money transmitters.
2. Customer - The proposed definition defines "customer" as any
person seeking to open an account and any "signatory" on an account. The
regulations should not require recordkeeping for situations where an individual does not
actually receive bank services. The final rule should exclude coverage for those simply
seeking information or that are denied requested services.
3. Signatory - The coverage of all new signatories on an account is an
extreme problem. Arguably guarantors on loans could be covered under the current
definition. In addition, the verification and recordkeeping in cases where there are
numerous (and frequently changing) signatories will be extremely expensive and labor
intensive. We believe thee is a need for a "risk-based" response to the issue of
signatories.
4. Copying of driver's licenses and other U.S. documents
- As our bank has discussed the proposal, we believe this requirement will necessitate the
maintenance of a central file on customers to avoid the appearance of a Regulation B
violation. The cost of copying this information and maintaining such a file will be
burdensome. We recommend that instead of requiring the copying and retention of documents,
that the account application or signature card be allowed to be used to note the document
used to verify identity.
Sincerely,
Kim Parker, Compliance Officer
High Point Bank and Trust Company
300 N. Main Street
High Point, North Carolina 27260
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