Question: We have customers that have heard about the KYC proposal and are very upset. They want to send in comments. Do they write to the same address that banks do?
Answer: Yes. The comment process for a rule such as KYC is required by the Administrative Procedures Act. Think of it as compliance for federal agencies who want to make rules. They have to follow certain procedures, including proposing the rule for comment, receiving comments, evaluating comments (yes, someone has to read and analyze all those letters) and making adjustments to a final rule that accommodate or reflect the comments.
The comment period is your chance for revenge. Every letter that gets written must be read. Mind you, the regulators get a quick nose for letters that simply let off steam. But the responsible regulator will be looking for information and fact situations that can be used to structure the rule more effectively.
Give any interested customers the addresses listed in the proposal. The customer - and your institution - can comment to any and all of the regulators. All of you - customers and banks alike - are members of the public who are invited to comment. You are not restricted to your regulator.
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