General Comment: This responds to your request for comment about the proposed Model Privacy Form. The form would determine the right of certain financial institutions to share personal information with affiliates and others.

I believe that the proposed form has it backwards. As I understand it, the form would permit that sharing unless the customer checks the boxes on p. 3. It should be the other way around, with the sharing barred unless the customer checks the boxes.

It's unfair to subject people to potentially harmful action unless they act to prevent it. The default should be to prevent that action unless the customer affirmatively acts to permit it. This form, like so many other things, is an indication of the extent to which the government is in the pocket of big business.

Richard Pu, P.C.