Comment Text:
Regretfully, I missed your previous NPRM on this subject. After briefly reviewing some of the comments submitted, I contest to their reasoning on this subject of being costly and burdensome regarding the identification information of datapoints, their date of birth, etc... If this is a problem for the respondents, it only means that customer due diligence has never been performed, nor was it intended to be performed as to who exactly the owner is. This is basic and fundamental. When an individual opens a bank account/deposit agreement and completes a signature card, this is the information that is asked of them; along with their SS#. When the customer hasn't been defined and the account is the institution's capital trust account, the owner is, or should be listed in the trust ledger. With this being said, the privacy impact assessment would attach the two lines of information; being the employer (customer), the employee (the institution) and the personally identifiable information of both. With the amendment of the Privacy Act of 1974 SORN and name changes to the information systems, it paves the way for clearing conflicts of interest and definitive customer statements, thereby, revalidating the entire process of who is in control. The institution and the advisors are agents for the customer. The Estate holds long security and cash posititions. The beneficiaries of the Estate are owed security position reports and other required disclosures relating to cash positions, the nominees that hold the accounts and the perrogative of direct registration. It's fundamental.
