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
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