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FDIC Federal Register Citations Glenview State Bank I am truly in disbelief that a considered change in the model privacy form is not accompanied by some common sense. I have read thru the handful of comments submitted so far, and while I will interject some opinion, it has already all been laid out for you in just a handful of responses to date. Other comments out there also discuss the ridiculous waste of money and natural resources as a result of the proposed change, never mind the waste we already experience under existing rules. I am glad, to date, that there is no "form letter" response to this issue, because maybe then you will realize that we are all trying to tell you the same thing. Everyone of us is bombarded with privacy notices in the mail. I would confidently guess that most go completely unread. Community Banks in particular are under enormous pressure to compete in today's banking environment, and while regulations are necessary and important, they should not cause undue burden. Complying with the enormous amount of existing and new regulations is our responsibility, I grant you that. But in this case, it seems that there is a very clear compromise: o Require us to provide a notice to the customer no later than when a customer relationship is formed o Require us to Provide an annual notice to the customer ONLY when there is a change in the financial institution's privacy practices o Require us to have Privacy Policy Statement available at branches, on our web site and upon a consumer's written or oral request o Allow us to use your model language, but in a format that saves paper, reduces postage burden, and does not require that we throw away everything we spent money on and worked hard on to create. The changes get frustrating - sometimes it seems like changes are made just so marketing companies around the country can fill our mailboxes up even more with their "approved Privacy brochure - customized for your institution - hurry, the new regulation takes effect soon!". Again, regulations are crucial - I don't oppose them. Quite the opposite, in fact. I embrace them because, as an example, in the case of Reg Q, it prevents unfair marketing competition. Simply said, I feel strongly that regulations should have an element of common sense built in. If I could just go about my business of trying to keep my customers happy and provide them with quality banking services as opposed to spending money on compliance brochure revisions and mailings that go unread, I might just be able to add some real value to the work I do for my employer. David Kreiman |
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| Last Updated 05/03/2007 | Regs@fdic.gov | |