From: Oak Creek Valley Bank [oakcreek@inebraska.com]
Sent: Friday, April 23, 2004 6:14 PM
To: Comments Subject: privacy notices

Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

ATTN : Comments/Executive Secretary Section

I apologize for the lateness of my comment on Privacy Notices (beyond the April 16, 2004 deadline), but hope this comment will still be considered.

Has there been any discussion or consideration, not to creating a "uniform" or "Model" notice, but to eliminating the Privacy Notice requirement entirerly - at least as it relates to small Community Banks (Under $250 Million for example) who do not share their information and who have no affiliates.

This entire need for Privacy Notices is driven by the outrageous action of one Bank that I believe paid dearly for their actions in negative publicity and other costs. Continuing to heap yet another requirement on over-burdened and overregulated institutions does little if anything to help consumers where the information provided in most all privacy notices is so vanilla and so generic and in most cases so overly broad that it actually provides little or no useful information to consumers.

I have personally received nearly a dozen notices or more from insurance companies; banks; brokers; etc. These entities range in size from very small companies (1 branch/office & a few employees) to Huge multi-state entities with numerous affiliates/subsidiaries and business arrangements. Yet, the notices from all of these entities already look virtually identical. Even though I understand this regulation and was involved in developing our Bank's policy and notice, I felt that the notices provided to "me" as a consumer were a complete waste of time, effort and money which could no doubt be spent much more wisely given the current world situation. Making these notices more similar necessary makes them less specific and less meaningful.

Out of over 1,000 notices sent, our institution received no more than a handful of comments from customers all of whom believed we were doing "more" sharing of their information than we actually were due to the required language we had to use in the notices.

Given my belief that these notices are thrown away by far more people than the number who read them I would support eliminating the notices to the extent permitted and/or extending the time between when they must be sent. In other words every 3 years or 5 years, not every year. Clearly a cost/benefit analysis needs done on Privacy and I DO NOT BELIEVE THE HIGH COST IS WARRANTED BY THE VERY MINIMAL BENEFIT.

Sincerely,
Mark Blazek