FDIC Federal Register Citations

FamilyFirst Bank

From: George Staiti [mailto:gstaiti@warecoop.com]
Sent: Tuesday, May 08, 2007 4:02 PM
To: Comments
Subject: Model Privacy Form - RIN 3064-AD16

FamilyFirst Bank
40 Main Street
Ware, MA 01082-0849

Robert E. Fieldman, Executive Secretary
Attn: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

RE; Model Privacy Form

Dear Mr. Feldman:

I appreciate the opportunity to comment on the Interagency Proposal for Model Privacy Form Under the Gramm-Leach-Bliley Act. This Interagency Propsal is directed by Section 728 of the Regulatory Relief Act.

I find the Model Privacy Notice to be adequate in format.

However, I find the form cumbersome, for delivery purposes. The form should be designed to fit on the front and back of one page, rather than using multiple pages, and provide space for a financial institution’s logo. Multiple pages become costly to small institutions like mine.

The requirement to provide annual notice should be eliminated, and perhaps replaced with the requirement for an initial notice at account opening, then again only if an institution changes its policy, and upon request by a consumer. For small institutions like mine, this annual mailing is both costly and time-consuming. This is the only notice requiring annual delivery to customers and is a prime candidate for regulatory relief.

Respectfully submitted,

George P. Staiti
Assistant Vice President
FamilyFirst Bank
413-967-6271
GStaiti@FamilyFirstBank.com