From:                                         Shireen Hartmann [shartmann@summitstatebank.com]

Sent:                                           Monday, March 14, 2011 3:21 PM

To:                                               Comments, Regulation

Subject:                                     Attention:  CTR Database

 

Attention CTR Database – In response to the request for comments concerning Bank Secrecy Act Unified Currency Transaction Report Proposed Data Fields.

 

I have reviewed the proposed fields and find some to be burdensome for the employee’s of  financial institutions’ to collect.

 

The following additional fields are intrusive, burdensome, and should not be added to the CTR form:

 

Part I -

Field 7 – Gender

Field 9 – Occupation or type of business a. NAICS code

New Data Element of County-Derived through third party data

New Date Elements for GEO Coding-Derived through third party data

New Data Element of HIFCA code-Derived through third party data

New Data Element of HIDTA code-Derived through third party date

Part I-Section B

Field 18, 18a and 19, Contact phone, Ext. & E-mail address

 

Part III Financial Institution Where Transaction(s) Takes Place-

New Data element of County-Derived through third party data

New Data element of GEO Coding-Derived through third party data

New Data element of HIFCA-Derived through third party data

New Data element of HIDTA-Derived through third party data

 

Financial Institutions’ are already overburdened with information gathering, please do not increase this burden by adding the above data fields to the Currency Transaction Report

 

 

Thank you for taking the time to review my comments.

 

Sincerely,

 

Shireen Hartmann

 

Shireen Hartmann AVP, Compliance Administrator

Summit State Bank

500 Bicentennial Way | Santa Rosa, CA  95403

Direct 707.568.4946 | Fax 707.573.4631

shartmann@SummitStateBank.com  www.SummitStateBank.com

 

Your local bank - Your community bank.

 

 


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