Our bank is a small community bank in central Texas that has never sold or
otherwise provided, customer information to outside entities other than to
vendors who help us provide bank products to our customers. The added
expense and regulation associated with GLBA is particularly frustrating
since we do not share customer info with anyone outside the bank yet we
still have to send disclosures to our customers each year telling them we do
not share their information.

While we understand that the intent (to protect customer information) of
this legislation was certainly good, it seems that the original purpose of
the legislation could be enhanced by making one very small amendment to the
existing law.

My suggestion would be to require only those banks who plan to sell or
otherwise provide their customers information to outside entities to send
out an annual disclosure.

This would have two significant benefits

1. Eliminate costly overhead and regulation for the banks that do not
disclose customer data anyway

2. Raise customer awareness and more succinctly communicate which financial
institutions were sharing their data. Currently, since all financial
institutions are required to send annual disclosures, the customer becomes
desensitized to the disclosure and is more likely to discard the notices
than read them. In other words if only the banks that were selling the info
were the only ones required to disclose annually, then the consumer would
know immediately which financial institutions were selling their data and
could act quickly and more efficiently to stop the activity if they
objected to it.

James Marek
VP
City National