W000131
Tuesday, November 06, 2001 4:32 PM
Proposed Regs
I have read the Act and believe that there are numerous administrative
problems as it is now written. These problems do not include the far
more potentially serious situations that may develop if indeed there are
further acts of terrorism. How will potential future victims be
compensated?
As to the current problems; as an administrative trust officer I know
all too clearly the potential for not getting all the truth in an
attempt to receive "discretionary" funds. By putting any time
constraints on any investigative attempts is inviting a real attempt at
fraud. While there should be some relief given to victims and their
families for immediate needs, there needs to be a longer period for
determining final payment amounts. Additionally, these final awards
should not be determined by a single individual, but instead should be
determined by a committee of individuals not to exceed five. Any larger
group is also inviting a non-efficient working atmosphere.
I also believe that the government needs to consider what awards (if
any) individuals will receive from charitable sources. This information
will also take considerable time to collect, particularly when you
consider that these charitable groups themselves are largely ill
equipped to remit funds currently. In the alternative, the government
should have a program in place to advise the charitable entities of any
funds which have been (or will be) paid to an
individual/survivor/estate.
I would suggest that a possible remedy would be to register funds paid
to any claimant (subject to a maximum amount to be determined) prior to
a determination of a final amount. These funds would effectively be
treated as interest free loans prior to a final payment. Any funds
extended which subsequently were found to be inappropriate, would be
subject to repayment (and if necessary wage garnishment, etc.).
There also needs to be established just who the proper beneficiary is.
A child who lost a parent should quite possibly have funds paid to a
third party who cannot spend any funds inapproprately. A payment
directly to a surviving parent/guardian unfortunately does not guarantee
that the future financial needs (college, etc.) of an orphaned child
will be met.
The purpose of this writing, therefor, is to suggest that only an
"immediate critical needs payment vehicle" be established at the current
time. This vehicle also needs to be in the form of a loan until the
final restitution circumstances are determined. There also needs to be
established a clear set of guidelines for payment, maximum payment
amount(s), appropriate beneficiaries/administrators (non-governmental
personnel and regulations - the private sector can handle these duties),
and co-ordinated programs with the private/charitable organizations
among I suspect many others. I believe that this temporary vehicle
satisfies the intent of the Act, while allowing development of long-term
efficient guidelines.
Individual Comment
Madison, NJ