FDIC Federal Register Citations

First Co Bancorp, Inc.

From: Darlene Larsen
Sent: Thursday, April 26, 2007 5:05 PM
To: Comments
Subject: Model Privacy Form - RIN 3064-AD16

May 26, 2007
From: Darlene Larsen
To: Comments
Subject: Model Privacy Notice

We, the individuals responsible for maintaining the compliance of a community bank, are appreciative of the opportunity to express our views of the proposed changes to the annual Privacy Notice. Many banks have limited resources to implement changes that are both costly and time consuming. In fact, is the need for an annual Privacy Notice even necessary? Banks are required to provide consumers with a privacy notice at the time of account opening. This should inform the consumer of our intent to share their personal information and provide them with the opportunity to opt out. If a company decides to change their privacy policy, they should then be required to disclose these changes to their customers.

The proposed Privacy Notice not only requires banks to change the notice that they are currently using but completely restructures the format, size and number of pages of the notice. That means we will need to completely change our current Privacy Notice. This will also cause additional expense to an already expensive process in areas such as salary, printing fees, postage and wasted paper.   Plus, with the proposed Privacy Notice printed only on one side of the page, opportunities for banks to use all available space to share information with our customers will be lost.

In addition to the changes and expense that the banks will be responsible for, consumers will have to adjust to yet another change in the information that they receive. We feel that this will not only be burdensome to banks but confusing to customers.

Darlene Larsen
Compliance Officer
First Co Bancorp, Inc
800 Beltline Road
Collinsville, IL  62234