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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

TAYLOR BANK

January 15, 2004

Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

RE: 12 CFR Part 332 RIN 3064-AC77

Dear Sirs:

I have reviewed the proposal seeking comments on making the privacy notices easier for consumers to understand and wish to make the following comments:

• Under the current rules it already requires the notices be "clear and conspicuous" and gives sample language. However, if you provided a basic format for institutions that only share non-public personal information where allowed by exception (which would include all financial institutions) and from there include different scenarios of sharing information outside the allowable exceptions and a "standard" easy to read language for the readers (consumers), it would lower legal and consultation costs for financial institutions in developing these notices, while providing the consumers with more meaningful and standard information.

• However, making it mandatory to use an "exact" language rather than allowing financial institutions the flexibility to use their own "clear and conspicuous” language that meets the required elements, would also be a mistake since they may have already invested much money and resources in their current notices that may already easy to understand.

• The biggest change that I would recommend would be to eliminate the annual notice requirement or change it to a less frequent period. The customers are provided the notice when the relationship is established, so providing it on an annual basis is wasteful because often they are ignored and discarded because the are receiving the notices too often. It would be more beneficial to the customers and be more cost effective for the financial institutions to provide the notice at account opening and then as requested by the customers in the future.

Sincerely,

Kurt B. Kormann, CPA
Compliance Officer
Calvin B. Taylor Banking Company
Berlin, MD
 

Last Updated 02/02/2004 regs@fdic.gov

Last Updated: August 4, 2024