From:
Matt Taylor
Sent: Friday, January 09,
2004
9:59 AM
To: Comments
Subject: FDIC comment on
privacy notices
Jan. 9. 2004
Mr. Robert E. Feldman, Executive Secretary
comments@fdic.gov
FDIC
550 17th Street, NW
Washington, DC 20429
ATTN: Comments/Executive Secretary Section
This is to comment on the considered proposals
regarding alternative privacy notices that banks send to consumer
customers.
We feel the that the current regulations regarding
consumer privacy notices are unnecessary to consumers and burdensome to
financial institutions. Although we take seriously the actions
recommended to protect consumers’ privacy, we do not believe that
providing an annual written privacy notices to consumer customers is a
relevant solution to any problem. Producing and delivering these notices
consumes a tremendous amount of our bank’s resources and time, and some
of our own customer have stated to us that they ignore these notices.
Any idea for making notices more “useful” to consumers is flawed from
the beginning – they simply are not useful now to the majority of
consumers, and therefore should not be required.
That said, any effort to simplify our compliance
with this regulations should be explored, but with some discretion. The
amount of text in our notice is already short, but nonetheless requires
the same amount of time and energy to produce and deliver as would a
longer notice.
We do not see how a standard notice that is used by
all financial institutions could be implemented. There is no way a bank
the size of Bank of America, for example, uses same privacy protection
techniques as is used by a relatively small bank likes ours. We are a
bank that does not use terms like “corporate family,” but bigger banks
surely would use those terms.
The opt-out possibilities are confusing to consumer
customers and burdensome to banks.
We request that regulators change these regulations
and ease the requirements placed on banks to provide privacy notices to
consumer customers.
Sincerely,
Matt Taylor, Privacy Notice Coordinator
Assistant Vice President
Denison State Bank
421 New York Ave
Holton, KS 66436
