Federal Deposit
Insurance Corporation

Federal Deposit Insurance Corporation
Attention Comments/OES
550 17th Street, N.W.
Washington, DC 20429

Re: Comment on Proposed Rule on Customer Identification Program
Section 103.121(b)(3) - Record-keeping

To Whom It May Concern:

Please accept the following as our comment on the proposed rule affecting Customer Identification Programs, and specifically the record-keeping requirements of Section 103.121(b)(3):

The proposed rule would apparently require a bank to maintain a copy of the identity document, such as a valid driver's license, that the institution relied upon to verify the identity of the customer seeking to open a new account. The institution must copy the document and maintain that record for a period of five years after the account is closed.

As an alternative to this requirement, we would suggest our current practice for maintaining a record of the identity document used to verify a customer's identity. We utilize a new account application, which is completed for all new customers and contains all the types of information that would be required by the proposed Customer Identification Program rules. Bank personnel request two forms of valid, current ID, which are compared to the individual(s) applying to open a new account. Information from these identity documents is recorded on the application form including the entity that issued the ID and the identifying number from the ID. A consumer report is obtained for the applicant(s) from a credit bureau or other consumer reporting agency to confirm the validity of Social Security numbers and to compare name(s) to government lists of known or suspected terrorists. The date and the results of the consumer report are also recorded on the new account application. If there are any discrepancies between the information supplied by the applicant and the methods used to verify that information, a record of resolution of those discrepancies is also made on the new account application. All information collected and recorded on the form is then maintained in our records for the period of time required by our record retention program.

Although we routinely utilize identity documents to verify customer identity and the information supplied by account applicants, it is not currently our practice to copy and maintain a physical record of those documents. We feel the procedure outlined above adequately addresses the intent of the proposed regulation without the imposition of additional burdensome recording-keeping requirements for physical documents.

Thank you for allowing us to present this comment for consideration.

Sincerely,

David J. Gonyaw
Vice President & Compliance Officer
Passumpsic Savings Bank
497 Railroad Street, P.O. Box 38
St. Johnsbury, VT 05819
Tel. (802) 748-3196