From: richard.charsley@bankofamerica.com
Sent: Wednesday, September 04, 2002 5:01 AM
To: rule-comments@sec.gov
Subject: FW: Docket No. R-1128 (Fed Res) ; Docket No. 02-13 (OCC) ; File
N o S7-32-02 (SEC)



  -----Original Message-----
 From: 	Charsley, Richard  
 Sent:	04 September 2002 09:47
 To:	'regs.comments@federalreserve.gov'; 'regs.comments@occ.treas.gov';
 'rule-comment@sec.gov'
 Subject:	Docket No. R-1128 (Fed Res) ; Docket No. 02-13 (OCC) ; File
 No S7-32-02 (SEC)
 
 Questions in respect of the above draft 'White Paper'.
 
 1. Did initial interviews take into account vulnerability and consequences
 on the US Banking system for those major banks with 'out-of-country' IT
 and global networking presence? If so, are there likely to be any separate
 recommendations relating to those Operations?
 
 2. The implication is that the timeframe for issuance of White Paper and
 incorporation into 'supervisory expectations' will be accomplished by end
 of 2002 with another 6 months (180 days) for institutions to adopt within
 their implementation plans. The proposed timeframe of 2007 for full
 implementation in cost effective manner appears excessively generous when
 given the nature of the risk and the fact that only 'core' major banks and
 security firms are addressed.
 
 Richard Charsley,
 International Information Security,
 Bank of America,
 U.K.         
 
 
 
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