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Camilla: I read the web page on the proposed change. I was a senior
commercial bank officer for 28 years, retiring seven years ago. The
money laundering rules originally required banks to report $ 10,000.00
cash deposits. This was done to catch criminals , primarily in the drug
trade. Once they have the cash in the bank, they are able to wire
transfer it around the world without detection by the authorities. At
that time, trucks were backing up to the back door of Florida banks with
loads of cartons full of currency.

The criminals adapted to the $ 10,000 rule by going to the various
branches of a large bank with $ 1,000, $ 2,500 and $ 5,000 deposits. The
Feds than required banks to develop computer programs which would
accumulate all the cash transactions of a customer.

I have been out of the loop for seven years, but I read the rule as
forcing all banks to observe the rules. My bank, Fleet Financial, is the
10th largest bank in the country. Banks this size have to obey the rules
, or their mergers will not be approved by the Feds. There are thousands
of the small institutions , who advertise how friendly they are, but do
not always obey the rules.

I have no sympathy for the criminals who sell drugs to our society. I
have even less sympathy for those so called respectable financial
institutions who will not report money laundrying which may be criminal.
Many respectable businesses deal with large quanity of cash deposits.
This asks that the banks know their customers to be sure cash deposits
are legal transactions. I have not known many individuals, other than
legitimate businesses, who require constant large deposits of cash. The
Feds may need to finetune this rule, but it sounds like they want all
financial institutions, commercial banks, S& L's and credit unions, to
have a level playing field. Their purpose is to flush out the criminal
element and those trying to cheat on income tax.