FDIC Federal Register Citations

From: KimC@theBank-louisiana.com [mailto:KimC@theBank-louisiana.com]
Sent: Thursday, May 10, 2007 10:28 AM
To: Comments

Subject: [Docket No: R-1280];[FR Doc: 07-01476];[Page 14939-15000]; Privacy of consumer financial information; model privacy form

We as a community bank and committee for the bank worked very hard to design a Privacy Policy for our institution that was a custom fit for us. There was a lot of time spent reviewing vendor contracts and making sure that we understood where the information we collect on our customers stays and goes and for what purpose. We have been sending these notices annually as required and daily with all of the new accounts that we open. Our customers seem to have a good understanding for our notice and feel confident that we are maintaining their records securely and are not sharing information for any other purpose then the purpose requested. I have reviewed the model notices and find that they would might our customers to believe that we are doing something with their information that we have not done in the past. I'm sure most bankers have worked as hard as we have in designing their own notices and have circulated them to their customers since the law required. If we choose to continue to use our The Bank Privacy Policy, we can not take advantage of the "safe harbor" legal aspects, so in my opinion it's not a choice, we will always do what is best for our bank and customer base. If the government wanted to design and implement a model privacy policy, why not at the time the regulation was mandated rather then years after we have all taken the time to prepare a policy and have all gone to the expense to educate, train and design our own institution policy. Thank You Kim L. Chiasson, Compliance Officer.