From: Thurlow, Julie
Sent: Tuesday, January 27, 2004 1:03 PM
To: Comments
Subject: Response to Interagency ANPR to Consider Alternative Forms of Privacy Notices under GLBA

To whom it may concern,

I am opposed to the above referenced proposal as published in the Federal Register page 75164 for reason set forth as follows;

1. Any standardized documentation should have been generated and included in the original rulemaking. Banks have undertaken hard cost including legal, printing and internal audit costs and significant staff time and expense to comply with the original rules. Furthermore, I suspect every institution has undergone an examination since the date of the original ruling and been granted adequate time to adjust their notices to comply with the original intent and any subsequent modifications.

2. The proposed rulemaking and standardized document will require each institution to bear the burden of additional costs of compliance when its current documentation satisfactorily communicates the purpose of the law as it relates to a specific institution.

3. The suggested standard form is excessive for smaller institutions that do not share customer information. This proposal increases the financial burden on smaller institutions. Furthermore, the requirement to use this 3 page format in lieu of the simplified privacy statement allow for institutions that do not share with affliates or others would increase the confusion to its customers.

Again, I am not in favor of a legislated template for the privacy disclosures. If you have any questions or require clarification of the above, please do not hesitate to contact me at (781) 942-5008, ext 108.

Sincerely,

Julieann M. Thurlow
Senior Vice President
Reading Co-operative Bank
180 Haven Street
Reading, MA 01867
jthurlow@readingcoop.com
781-942-5000 telephone
781-944-1401 facsimile