From: Shireen Hartmann [email@example.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.
Shireen Hartmann | AVP, Compliance Administrator
Summit State Bank
500 Bicentennial Way | Santa Rosa, CA 95403
Direct 707.568.4946 | Fax 707.573.4631
Your local bank - Your community bank.
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