PATRIOT Act Section 312 NPRM Comment file On June 12, 2002, the representatives of the financial services industry listed below met with representatives of the Treasury Department to present their views on the issues set forth in the attached memorandum regarding Treasury’s Notice of Proposed Rulemaking under PATRIOT Act Section 312. The Treasury representatives included General Counsel David Aufhauser, Deputy General Counsel George Wolfe, Deputy Assistant Secretary Julie Myers, and representatives of Domestic Finance, Office of General Counsel, and FinCEN. Following the presentation the Treasury representatives thanked the financial services industry representatives for their comments. Financial services industry representatives (representing the trade associations listed in the attached memorandum): Joe Alexander Derek Bush John Byrne Rodgin Cohen Julie Copeland Elizabeth Davy Thomas Delaney as Farmer Satish Kini Gregory Meredith Mihal Nahari John Huffstutler Richard Small Todd Stern Richard Whiting Barbara Wierzynski Treasury/FinCEN Proposed Rule under Section 312 of the USA PATRIOT ACT #3a Issues of Primary Significance Jointly Identified by Leading Financial Institution 1Trade Associations 1. Timing of Implementation of Proposed Rule. Issue: • Broad scope and retroactive application (i.e., to existing accounts) of Proposed 2Rule render compliance by July 23, 2002 impossible. Proposal ...