From: Tom Roth
Sent: Thursday, February 26, 2004 9:44 AM
To: Comments
Subject: 12 cfr part 332 PROPOSED RULEMAKING RE: SECTION 502 AND 503
OF GLBA
IT SEEMS THE REQUIREMENT TO PROVIDE AN ANNUAL PRIVACY NOTICE TO
OUR CUSTOMERS REPRESENTS A WASTE OF TIME AND RESOURCES. AFTER ALL,
DO ANY OF US ACTUALLY REVIEW THE NOTICES WE FREQUENTLY RECEIVE? I
DON'T AND I HAVEN'T MET ANYONE WHO CLAIMS THEY DO. RATHER, VIRTUALLY
EVERYONE SAYS THEY SIMPLY THROW THEM AWAY.
IT MAKES SENSE TO PROVIDE A ONE-TIME NOTICE AND TO PROVIDE THE
OPT OUT OPPORTUNITY. IT ALSO MAKES SENSE TO REQUIRE A NEW NOTICE
IF AND WHEN AN INSTITUTION MAKES A CHANGE THAT WOULD IMPACT THE
SHARING OF INFORMATION. IT DOESN'T MAKE SENSE TO SEND THE SAME
NOTICE OUT YEAR AFTER YEAR. REMOVING THE REQUIREMENT TO SEND AN
ANNUAL NOTICE WOULD SAVE CONSIDERABLE TIME AND RESOURCES WITHOUT
COMPROMISING THE BASIC REQUIREMENT OF PROVIDING NOTICE. THANK YOUN
FOR THE OPPORTUNITY TO COMMENT.
