via e-mail
READING CO-OPERATIVE BANKFrom: Thurlow, Julie
Sent: Tuesday, January 27, 2004 1:03 PM
To: Comments
Subject: Response to Interagency ANPR to Consider Alternative Forms of
Privacy Notices under GLBA
To whom it may concern,
I am opposed to the above referenced proposal as published in the
Federal Register page 75164 for reason set forth as follows;
1. Any standardized documentation should have been generated and
included in the original rulemaking. Banks have undertaken hard cost
including legal, printing and internal audit costs and significant staff
time and expense to comply with the original rules. Furthermore, I
suspect every institution has undergone an examination since the date of
the original ruling and been granted adequate time to adjust their
notices to comply with the original intent and any subsequent
modifications.
2. The proposed rulemaking and standardized document will require
each institution to bear the burden of additional costs of compliance
when its current documentation satisfactorily communicates the purpose
of the law as it relates to a specific institution.
3. The suggested standard form is excessive for smaller institutions
that do not share customer information. This proposal increases the
financial burden on smaller institutions. Furthermore, the requirement
to use this 3 page format in lieu of the simplified privacy statement
allow for institutions that do not share with affliates or others would
increase the confusion to its customers.
Again, I am not in favor of a legislated template for the privacy
disclosures. If you have any questions or require clarification of the
above, please do not hesitate to contact me at (781) 942-5008, ext 108.
Sincerely,
Julieann M. Thurlow
Senior Vice President
Reading Co-operative Bank
180 Haven Street
Reading, MA 01867
jthurlow@readingcoop.com
781-942-5000 telephone
781-944-1401 facsimile
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