Comment on FR Doc # 2012-05187

The proposed regulation reflects merit in the proposed result however the yield will only serve to increase the resource demand on an already taxed and strained process. The purpose for this regulation is to gain a greater knowledge of the higher level of criminal. The master benefactor of the illigal activity. History reflects that in terrorist financing, money laundering or any other crime those individuals are so insulated they are never disclosed. When a person enters our bank with criminal intent he does not present truthful information. Their mission is to use the bank to accomplish the task and achieve success. And failure is certain if all was disclosed. Our CIP program today requires us to research the information given to achieve a true understanding of all parties and the purpose of the account. This regulation will produce one more line on an application that says " Are the persons named on the account the benefical owners of the funds that will transaction in this account"? The criminal will always check yes. The true person will ask what does this mean, we will explain, it is required , they will be affended because they already feel as if we strip them down and filter through their private lives. And then they will state "OF Course! i am the beneficial owner. Audit will have to add this to their scope, examiners will have to include it in their scope. One more step to be criticized for and the ending result will be: we will not have any more information that we do today just more work for all involved. Detection does not happen on entry, you taught us that. Banks need means available to research criminal backgrounds and histories on individuals so we can make a risk based decision whether they could be bad or good. If we are to be treasury agents give us the resourses needed to be effective.