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Northrim Bank

From: Bailey, Julie [mailto:bailey.julie@nrim.com] 
Sent: Thursday, June 17, 2004 2:31 PM
To: Comments
Subject: RIN 3064-AC77 

I would like to submit the following comments on this proposed rule.

Appendix B to Part 364, III G (3). I believe the effective date of incorporating "disposal of consumer information" into a bank's information security program should not be the proposed 90 days after the final rule is published. Instead, the effective date should be when each institution has it's next scheduled presentation of the information security program to the board for approval. The board already is inundated with compliance related policies, procedures and programs, and adding an extra review and approval for this section to the annual approval they already give (each April for us) to the Information Security Program is unnecessary.

Julie Bailey, CRCM
VP, Community Development and Compliance
Northrim Bank
3111 C Street, Anchorage, AK 
 

 

Last Updated 06/22/2004regs@fdic.gov

Last Updated: August 23, 2024