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#100912 - 07/25/03 04:03 PM Treasury Comments
Kara S Offline
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Joined: Oct 2002
Posts: 927
Milwaukee, WI
I was curious as to how many BOLers submited comments to the Treasury by August 21st? Also, did you comment on both subjects or just one? If so which one?
When should we expect the Treasury to comment on the comments?

I only wrote about the Matricula Consular and how it is affecting the banking world.
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#100913 - 07/25/03 04:21 PM Re: Treasury Comments
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
We wrote only on the document retention issue. I am filing our comment letter today.
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#100914 - 07/25/03 04:26 PM Re: Treasury Comments
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
We will be submitting ours next week - only on the record retention question. I believe comments are due by July 31st.
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#100915 - 07/25/03 04:48 PM Re: Treasury Comments
Anonymous
Unregistered

I responded to both questions and sent them off last week.

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#100916 - 07/25/03 04:52 PM Re: Treasury Comments
Andy_Z Offline
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Posts: 27,748
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On 326 the month end is the deadline. My draft is submitted for review not to the HC and lobbyists we use.

I basically recommend banks get a choice of what they want, photocopy and choice of IDs.
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#100917 - 07/25/03 05:09 PM Re: Treasury Comments
thomasj Offline
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Joined: Mar 2001
Posts: 5,063
Pennsylvania
Sent one off this week on the record retention asking that we be allowed to decide if and when copies of ID are made. Also expressed my displeasure over why we were revisiting this when "Virtually all of the substantial number of comments relating to this provision were critical of the requirement."
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#100918 - 07/25/03 05:11 PM Re: Treasury Comments
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I sent a letter right after the comment period started.
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#100919 - 07/25/03 05:12 PM Re: Treasury Comments
Walleye Woman Offline
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Walleye Woman
Joined: Jul 2002
Posts: 832
I commented on both issues, sent early this week.
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#100920 - 07/25/03 05:18 PM Re: Treasury Comments
Retired DQ Offline
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Posts: 40,766
Turnpike Exit 10
Quote:

I commented on both issues, sent early this week.




Done last week.
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#100921 - 07/25/03 06:07 PM Re: Treasury Comments
Michelle D Offline
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Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
Commented on both issues and sent out on Monday. I also cc'd our local congressmen - both who are on the financial services committee with Sensenbrenner.
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#100922 - 07/25/03 07:11 PM Re: Treasury Comments
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
I commented on the identification issue.
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#100923 - 07/25/03 08:03 PM Re: Treasury Comments
Pale Rider Offline
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Posts: 34,318
under the Lone Star
We commented on both issues, and as Andy, we asked for the ability to determine what is appropriate, based on the risk assessment.
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#100924 - 07/28/03 04:00 PM Re: Treasury Comments
starfish Offline
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starfish
Joined: Jun 2003
Posts: 416
Seattle
I commented on both issues last week.

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#100925 - 07/28/03 04:19 PM Re: Treasury Comments
Midwest Offline
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Midwest
Joined: Jul 2003
Posts: 12
Midwest
We commented on both issues.

I would just like to add though, that even if you currently maintain copies of identification presented, i.e., copies of driver's licenses, you may still want to comment on that portion. If this is required, and you have a small branch with one broken copier, will you effectively have to shut that branch down until the copier's fixed? What about people in the field, opening accounts for the elderly or poor that can't make it into the office? Will have to go to the expense of supplying them with a portable copier? What if it breaks down? Please consider commenting on this issue even if you feel it doesn't pertain to your situation. The copying of identification should be the choice of the institution, based on risk, as it is now.

Thanks!
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#100926 - 07/28/03 04:37 PM Re: Treasury Comments
BeachGirl Offline
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Joined: Sep 2001
Posts: 206
Myrtle Beach, SC
I commented on both issues last week.
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#100927 - 07/28/03 06:56 PM Re: Treasury Comments
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
Slammin,
Treasury has not indicated any time frames, but usually the agencies give themselves a minimum of 60 days to consider what has been said. (They are under pressure from a powerful member of Congress, so that might shorten the time frame.) The regulations were jointly issued and cannot be revised without the concurrence of the other agencies. So, any proposed revision has to go through a gestation process of its own; Treasury cannot simply change the final regulation. At the end of this Notice Treasury indicated:

Only after considering all comments received in response to this notice of inquiry will Treasury determine whether to discuss with the federal functional regulators if it would be appropriate to jointly propose amendments to the final rules published on May 9, 2003, through a notice of proposed rulemaking. Financial institutions covered by the final rules are reminded oftheir obligation to be in compliance with the final rules by October 1, 2003.

Please note, Treasury isn't even indicating an intention to discuss the responses with the agencies until they make up their own mind. (Where's my Big Dog T-shirt?) In short, if the regs are revised, it will not be until well after October 1.

P.S. I commented on both.
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#100928 - 07/28/03 08:59 PM Re: Treasury Comments
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
Quote:

Slammin,
Treasury has not indicated any time frames, but usually the agencies give themselves a minimum of 60 days to consider what has been said. (They are under pressure from a powerful member of Congress, so that might shorten the time frame.) The regulations were jointly issued and cannot be revised without the concurrence of the other agencies. So, any proposed revision has to go through a gestation process of its own; Treasury cannot simply change the final regulation. At the end of this Notice Treasury indicated:

Only after considering all comments received in response to this notice of inquiry will Treasury determine whether to discuss with the federal functional regulators if it would be appropriate to jointly propose amendments to the final rules published on May 9, 2003, through a notice of proposed rulemaking. Financial institutions covered by the final rules are reminded oftheir obligation to be in compliance with the final rules by October 1, 2003.

Please note, Treasury isn't even indicating an intention to discuss the responses with the agencies until they make up their own mind. (Where's my Big Dog T-shirt?) In short, if the regs are revised, it will not be until well after October 1.

P.S. I commented on both.




Thank you, I'm not too sure where I read it, but I could have sworn the commentary period was only until August 21st...of course, I can not find my source now!
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#100929 - 07/28/03 09:03 PM Re: Treasury Comments
Bear Collector, CRCM Offline
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Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
I sent my letter today. We only commented on the photocopy issue - the other issue is just too much of a political "hot potato" around here, and we decided to leave that one alone and live with the results.
BC
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