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via e-mail
BAY STATE SAVINGS BANK
From: Pam LeBlanc
[mailto:pleblanc@baystatesavings.com]
Sent: Tuesday, March 02, 2004 4:02 PM
To: Comments
Subject: Alternative Forms of Privacy Notices
Thank you for the opportunity to provide comments relative to the
Interagency Proposal to Consider Alternative Forms of Privacy Notices
Under the Gramm-Leach-Bliley Act.
Bay State Savings Bank is a 6 branch, $245 million dollar local
community Bank with approximately 28,000 customers. We are currently
required to provide a Privacy notice to all new customers when they
establish an account with the Bank. We are also required to send an
annual mailing of our privacy practices to all customers. The Bank
utilizes a simple notice detailing the information we collect and that
we may disclose the information within the exceptions. We do not
disclose outside of these exceptions, therefore no opt-out is provided.
We do not feel it makes sense from a cost perspective for a Bank to be
required to maintain a short form of its privacy practices and also be
required to print and store a longer, more detailed version for those
who request it. The basic cost to us of providing an initial privacy
notice is $.13 per notice and with an average of 300 new accounts opened
and 100 loans established each month. This results in an annual cost of
$624.00 to provide the initial notice to customers, which we consider to
be a reasonable cost. This cost would increase considerably if we were
required to print and have on hand an inventory of long form notices
just in case we’re asked for it. Since the privacy rules went into
affect, we have had no comments/complaints from our customers indicating
that they did not understand our notices nor have we had any questions
relating to our current practices and disclosure.
For the required annual notice, as stated above, with a customer base
of 28,000 customers, the cost of printing a sufficient supply of privacy
notices is $3,640.00 plus the cost of postage of $10,360.00, makes the
cost increase considerably (Annual cost of $14,000.00). We are of the
opinion that it does not make sense to continue to mail the annual
notice unless the Bank makes changes, enhancements or revisions to its
policy or unless the Bank is required to include an opt-out provision
because they share information outside of the exceptions. Our experience
tells us that these notices often go ignored and are unread by consumers
since they are inundated with so many. As long as a Bank documents any
changes to its privacy notice and the date that the revised policy was
mailed, if necessary, this should be acceptable to regulators.
Thank you again for the opportunity to comment on this proposal.
Sincerely,
Pamela L. LeBlanc
Assistant Vice President, Compliance Officer
Bay State Savings Bank
Worcester, MA 01608
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