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FDIC Federal Register Citations

From: Diane Foltz
Sent: Tuesday, September 14, 2004 12:59 PM
To: Comments

Subject: EGRPRA Burden Reduction

Dear Mr. Feldman:

I appreciate the opportunity to comment on the efforts to reduce regulatory burden in our industry. I represent a $437 million community bank with seven offices in our county. Please consider the following in regards to your request:

Regulation H: We feel that getting the credit disclosure signed within three days is particularly burdensome. Many of our applications are taken over the phone and credit insurance is solicited at that time. Disclosures are sent within three days but are rarely signed and returned, especially if the loan is not originated. It is difficult and costly to send letters and make calls in an effort to get the disclosure returned. This disclosure should be eliminated and replaced with a disclosure signed at closing confirming the purchase of the insurance. However, even that seems to duplicate the requirements Regulation Z sets forth for the purchase of optional insurance. It does not feel, with today's requirements, that we are providing service to our customers when we require them to sign three disclosures (credit, insurance and Reg Z confirmation) just to confirm the purchase of insurance in connection with a loan on top of the forms required by the insurance company.

Regulation P: As stated in several other comment letters, the annual notice requirements for the privacy notices are very costly to our community banks, especially when the notice has not changed from the previous mailing. Giving consumers a notice at account opening and any time there is a change should be sufficient. Please remember that institutions have this notice on their website for consumers to review at their convenience in the event they need to. The annual mailing requirement could also be replaced with a lobby notice requirement. Again, with the website notice and a lobby notice, those interested would have multiple ways to access the notice while providing institutions with a substantial cost savings. We also oppose any amendments to the content or form of the notice that would make the requirements under the regulation more burdensome.

Safeguarding of Customer Information: Several areas here are burdensome and costly for community banks to comply with. Risk analysis, documentation requirements and vendor due diligence requirements are good examples. We understand that there is no "one size fits all" answer here, however the guidelines provide very little assistance in these areas leaving banks scrambling. Commentary and/or clarity of intent would be helpful here.

Regulation E: The quarterly statement requirement for savings accounts that have EFT capabilities but no EFT activity is a costly burden. We ask that you consider allowing savings account statements which have no EFT activity to be moved to a semi-annual or annual statement cycle.

Thank you for allowing us to comment on this topic. We hope to see action taken towards reducing regulatory burdens in our industry in the near future.

Sincerely,

Diane M. Foltz
Farmers State Bank
Compliance Officer

 

Last Updated 10/05/2004 regs@fdic.gov

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