From: Helen Stephan
Sent: Tuesday, August 03, 2004 2:53 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
The Gramm-Leach-Bliley
Act of 1999 established requirements for financial institutions
to provide new privacy protections to consumers. One of the requirements
if to provide privacy notices at the time of account opening and
on an annual basis. The initial mailing of privacy notices served
the purpose of notifying customers of a financial institution’s
privacy policy and, in certain cases, provided an opportunity to “opt-out” of
any information sharing.
A privacy notice is provided
to each new deposit account and loan customer at time of account
opening. My comment refers to the GLBA requirement to provide annual
privacy notices. After an institution has provided an initial privacy
policy notice, unless the policy changes, it seems redundant to
provide that same policy annually. The rule would be more meaningful
and efficient to send annual mailings ONLY if the policy changed.