Robert Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street
NW
Washington, DC 20429
Re: Comment Regarding FACT Act Disposal Rule
To Whom It May Concern:
After reviewing the proposed rules for the disposal of consumer information
it appears this is a lot of additional paper work for something
which has already been covered in the Gramm-Leach-Bliley Act Safeguards
Rule.
While there may be other entities that need this regulation to insure
proper disposal of consumer information banks have an Information Security
program in place that addresses the disposal of customer information.
Since we already
have an Information Security program in place that addresses the disposal
of "customer information," modifying
our program and policies so that we address the disposal of "consumer
information" is an unnecessary step given the fact that the definitions
of "consumer information" and "customer information" overlap.
Modifying our program
and policies to address the disposal of "consumer
information" is unnecessary because the definitions of "consumer
information" and "customer information" overlap.
Respectfully submitted,
Diana Fisher
Executive Vice President