FR 2025-05235

The document in question, issued by the Board of Governors of the Federal Reserve System, announces a request for public comment on a proposal. This proposal pertains to an extension of the Written Security Program for State Member Banks, formally identified as FR 4004 (OMB No. 7100-0112), for an additional three years without any changes. The primary aim of the program is to ensure that these banks have proper security measures in place to deter criminal activity and aid in prosecution when necessary. The board solicits comments on this proposal until May 27, 2025, inviting the public and relevant stakeholders to share their thoughts through various means. Subsequent analysis of the feedback will inform any potential amendments to the proposed extension.

Significant Concerns and Issues

One notable concern is the complex and bureaucratic language employed throughout the document, which may not be easily understood by individuals without a background in legal or administrative processes. This could present accessibility challenges to a lay audience who might struggle to comprehend essential details about the public comment process.

Furthermore, the document outlines multiple options for submitting comments, including through the agency's website, mail, hand delivery, and email. While this offers flexibility, it might also lead to confusion and inconsistent submission adherence among those not familiar with governmental processes.

Another pressing concern is the stated policy of making all received comments publicly available without redacting personal or business information. This lack of anonymity may deter individuals from submitting comments due to privacy concerns, as personal and sensitive information could be exposed.

The brief mention of estimated burden hours, as well as the lack of an in-depth explanation regarding the methodology used to derive these estimates, signals a need for greater transparency. Stakeholders would benefit from a more comprehensive understanding of how these figures were calculated.

Lastly, the document does not elaborate on the rationale for proposing a three-year extension of the program without revisions. Additional context about why this timeline is necessary, and the reasons behind maintaining the status quo, would help stakeholders better grasp the implications and needs justifying the extension.

Public and Stakeholder Impact

For the general public, this document's implications might be minimal unless they are directly involved with or have interests in banking security and regulation. However, the lack of clarity and the potential privacy issues in the comment process might discourage broader participation in this aspect of civic engagement.

For state member banks, the document's proposal will likely have more direct and notable consequences. These banks are the primary stakeholders, as they are required to establish and maintain security programs under FR 4004. While continuing the program is beneficial for ensuring bank security and compliance, the decision to extend it without changes could suggest a missed opportunity for improvement or modernization, which might be necessary in a rapidly evolving technological landscape.

In summary, while the proposal serves to maintain a security status quo, questions surrounding privacy, methodological transparency, and the rationale for an unchanged extension remain. Addressing these issues could help foster greater participation and ensure the program's relevance in safeguarding financial institutions effectively.