TO: THE EIGHT FEDERAL REGULATORS SOLICITING COMMENT ON THE
IMPROVEMENT OF PRIVACY NOTICES GIVEN TO CONSUMERS UNDER THE GRAMM-LEACH-BLILEY
ACT (the GLB Act).
The requirement of Section 503 of the GLB Act is a necessary and
important part of the Act. The complexity of the privacy policies of the
organizations required to provide privacy notices to consumers should
dictate the language in the notice and the frequency in which it should
be given.
Our financial institution regards our customers privacy with
importance. The Scottdale Bank & Trust Company does not share customer
information with any other organization outside the permissible
purposes. The goal of the privacy notice is to inform the customers of
the practices of that organization. This should be a priority of the
required notices.
Our experience has been the annual privacy notice mailings confuse
our customers instead of the positive results for which the Act was
established. The burden to our institution is the annual mailing of the
privacy notices. The general considerations for improving the contents
of these notices are important, but the frequency of which they are to
be mailed should also be a consideration. The cost to print the notices,
to process the mailers and the cost of the postage is approximately
$10,000.00 annually. This is the cost for a notice that has not changed
since the inception of the GLB Act. We recommend that the privacy notice
be given to each new customer at the time the new relationship is
established, and the only requirement for mailing a subsequent notice
would be if any changes have occurred in the institutions privacy policy
therefore requiring an updated, notice be mailed.
Sincerely,
Melinda Powell
Compliance Officer
150 Pittsburgh St.
Scottdale, PA 15683