Comment on FR Doc # E8-08955

Attention: Currency Transaction Reports Exemptions Rule and Form Amendments Thank you for allowing us to comment on the proposed changes to the Currency Transaction Reporting rules. As a small community bank with three locations in two counties of East Central Kansas, our staff wears many hats. Removing the requirement for biennial renewal of Phase II exemptions, will be a measure of true regulatory relief. It will save bank staff hours of time and therefore, money for each form we do not have to complete, check and re-check, and submit. We agree that notification of a change of ownership is necessary in exempt accounts. Therefore, a 30-day time period to file a renewal showing a change of ownership or control of an account makes sense. We also agree that the time period for exemption of Phase II customers should not be arbitrarily set as two months or 12 months or any other specified number. It should be left to the individual bank to decide how soon they feel they know their customer and the risks involved before an exemption is granted. The recommended revocation of an expired exemption never did make sense, but it does seem logical to revoke an exemption if there is no renewal time frame. We concur that the requirement to file an exemption for Federal, State and local governmental agencies, and entities exercising governmental authority is unnecessary. There cannot be any substantive value to law enforcement to report on the local county treasurer’s transactions. The risk public fund accounts pose to our bank is minute at best. We also believe that other financial institutions should not be subjected to the exemption filing process because financial institutions are already heavily regulated. Thank you for allowing us to submit our comments on this subject. Sincerely, James C. Wayman President ESB Financial