From:
Barb Finney
[mailto:BFinney@mwofg.com]
Sent: Friday, January 30, 2004 5:47 PM
To: Comments
Subject: Privacy Policy Proposal
Below are my comments regarding the proposed changes in Privacy
Policy requirements. Please forward onto the appropriate party:
I am responding to the public comment period currently open to the
public under the Gramm-Leach-Bliley Act as it pertains to annual privacy
notices.
An annual privacy notice requirement has put an undue burden on all
companies required to provide this document on an annual basis. This
burden comes in the form of excess labor, materials, and postage costs.
The only people winning under the current regulation are commercial
printers and the U.S. Postal Service. No one else.
My suggestion, would be the following;
Require an initial privacy notice to a new client of the institution to
be provided at the time the initial account or relationship is opened.
From that point forward, the only additional requirement would be if the
institution makes any material changes in it's policy in sharing
information; in essence, changing from the initial policy provided to
the consumer. At that point, a new privacy policy would be sent to all
customers notifying them of the change.
With all due respect, the current regulation is inadequate. Our
estimates are that a very small percentage of consumers who receive such
a voluminous document in the mail, actually read, let alone open, the
document. Those that do open the document, find little relevance as to
its content. At a minimum, I suggest an inexpensive (straw poll) survey
be completed of consumers to see what impact, if any, these mailings are
having. Only then, can an educated decision be made based on actual
facts. Why have regulations that only burden companies and confuse the
public.
Thanks for your consideration,
________________________________
Barbara A. Finney
Operations Officer
MidWestOne Financial Group, Inc.
Phone (641) 673-1504
Fax (641) 673-7836
bfinney@mwofg.com
