From: Bailey, Julie [mailto:bailey.julie@nrim.com]
Sent: Thursday, June 17, 2004 2:31 PM
To: Comments
Subject: RIN 3064-AC77
I would like to submit the following comments on this proposed rule.
Appendix B to Part 364, III G (3). I believe the effective date of
incorporating "disposal of consumer information" into a
bank's information security program should not be the proposed 90
days after
the final rule is published. Instead, the effective date should be
when each institution has it's next scheduled presentation of the
information security program to the board for approval. The board
already is inundated
with compliance related policies, procedures and programs, and adding
an extra review and approval for this section to the annual approval
they already give (each April for us) to the Information Security
Program is unnecessary.
Julie Bailey, CRCM
VP, Community Development and Compliance
Northrim Bank
3111 C Street, Anchorage, AK
