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IP: Letter to FDIC on Banking with Big Brother (wonder where there is a private bank anymore djf)
From: Dave Farber <farber () cis upenn edu>
Date: Sat, 26 Dec 1998 16:15:13 -0500

From: Declan McCullagh <declan () well com>

My article:


From: "Susan Lorenz" <slorenz () theriver com> 
To: <btirg () ui uis doleta gov>, <declan () well com> 
Subject: Re: Banking with Big Brother 
Date: Mon, 14 Dec 1998 11:34:09 -0700 

Here is a copy of the letter I just sent to the Office of Thrift Supervision,
the FDIC, and the FED.
Susan Lorenz

Sirs and Madams:

I read with interest in the Federal Register (7 December 1998) that you are
proposing substantial changes in the privacy of banking transactions.
Specifically, I understand that you are proposing that banks institute a "Know
Your Customer" Program that is substantially as follows: 
As proposed, the regulation would require each nonmember bank to develop a
program designed to determine the identity of its customers; determine its
customers source of funds; determine the normal and expected transactions of
its customers; monitor account activity for transactions that are inconsistent
with those normal and expected transactions; and report any transactions of
customers that are determined to be suspicious, in accordance with the FDIC s
existing suspicious activity reporting regulation. By requiring insured
nonmember banks to determine the identity of their customers, as well as to
obtain knowledge regarding the legitimate activities of their customers, the
proposed regulation will reduce the likelihood that insured nonmember banks
will become unwitting participants in illicit activities conducted or
by their customers. 
This, Sirs and Madams, is an OUTRAGE! A recent article, I think, describes it
This is the largest invasion of privacy in banking history. It is the
equivalent of a continuous roadblock in which the police search every car and
every person every day. Only this regulation is technologically worse, for it
will create computerized profiles of individuals that will sweep suspects into
lists of suspicious characters, and from there into criminal courts,
Now, I understand that the stated purpose of this proposed regulation is to
prevent "illicit activities" from being conducted in the Nation s banks, and I
favor the prevention of illicit activities. And, there is a limit to how much
invasion of privacy I will tolerate in order to prevent alleged illicit

I think that many of my fellow Americans will agree with me. We, for instance,
are willing to tolerate inconveniences such as metal detectors and luggage
searches at airports in an effort to prevent hijacking and terrorism. I
strongly doubt, however, that we would be willing to tolerate a strip
search of
every passenger prior to every flight, and this is what the proposed
amounts to.

I am a law-abiding citizen, and I am wearying of the ever-increasing
into my private life. Please withdraw the proposed regulation.

I am forwarding a copy of this letter to my representatives in Congress.

-----Original Message----- 
From: John Shaver <<mailto:shaverj () theriver com>shaverj () theriver com> 
To: Susan (river) Lorenz
<<mailto:slorenz () theriver com>slorenz () theriver com> 
Date: Monday, December 14, 1998 7:48 AM 
Subject: Re: Banking with Big Brother


Nev Dull wrote: 

Forwarded-by: Roland Grefer
<<mailto:btirg () ui uis doleta gov>btirg () ui uis doleta gov> 
Forwarded-by: Declan McCullagh <<mailto:declan () well com>declan () well com> 


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