Comment on FR Doc # E8-08955

Attention: Currency Transaction Report Exemptions Rule and Form Amendments We were very pleased to learn about the possible removal from 31CFR 103 of the biennial requirement to renew a designation for Phase I and Phase II exempt customers. This is a cumbersome process involving putting the due date on our email calendar as a reminder to remember to do this every other year and completing biennial form 110 paperwork on all of our exempt customers. Once the exempt form is filed we feel it should be effective until account closure and no other forms should be required. We don't feel any other forms should be required as it increases the paperwork burden to community banks. If it is the same business being exempt whether or not the owners of the business change and if the cash activity still supports the exemption, we feel no additional forms or renewals should be needed since it creates additional paperwork burden to community banks. We feel that no designated amount of time be required to file initial exemption as long as customer meets the designated number of CTRS filed and our analysis is based on a risk based approach as proposed. We would not exempt anyone unless we had a comfort level with their transactions. We monitor these customers that are filing CTRS and are aware of their cash activity. We feel 5 CTRs filed before considering an exemption is a reasonable guideline to follow. We feel the annual review of exempt customers for Phase I and Phase II customers is unnecessary since we monitor these customers on at least a monthly basis and use software now to help us detect suspicious activity. Performing an annual review would just increase the paperwork burden on community banks. We would still monitor for any suspicious activity on exempt accounts. We only have one government law enforcement customer and no banks who would be considered for exemption under phase I so proposals only affecting Phase I will not affect us greatly but if applied to Phase II would benefit us tremendously. We would like these comments to be considered in revoking the biennial filing requirement, change of control filing and annual review requirements for Phase II customers as well as Phase I due to increased software monitoring tools used in today's banking regulatory environment to detect suspicious activity. Thank you for considering our comments to lessen our paperwork burden under BSA exemption requirements.