FDIC Federal Register Citations

ShoreBank is very much in agreement with standardizing the Privacy Notice, including paper size, font standardization, color, etc. This will certainly provide the consumer an equal privacy policy comparison - and a much more “user friendly” document.

However, one comment ShoreBank would like to make is in regards to the Notice being provided to the customer in separate one side pages. One of ShoreBank’s core missions is “Conservation."

We would make the case that since the notice would be no more than two or three pages (for Opt Out), that even though the consumer expressed a “preference” for a one-sided, side-by-side view of the information, it would not be that difficult to compare a double sided copy.

For example, in 2006, ShoreBank printed approximately 36,000 Privacy Notices. We do not have an Opt Out, so our Notice is a “brochure” size, 4 sided notice (one sheet of folded paper).

If the revised Notice was allowed to be printed double sided, the following conservation gains would be accomplished (based on a savings of 36,000 sheets of paper):*

4.3 trees would be saved
500 kilowatt hours of electricity would be saved
750 gallons of water would be saved
7.5 pounds of air pollution would be kept out of the air

ShoreBank has 2 Billion dollars in assets. Imagine the above conversation savings that would be realized by a Bank of America or Wells Fargo, or all banks for that matter that would be required to use an extra sheet of paper to produce the new notice.

We strongly recommend printing the option of being able to print a double sided notice.

*Based on a savings of approximately 36,000 sheets of paper or 9 boxes where:

40 boxes= 1 ton and 1 ton of recycled paper saves 17.2 trees, 2000 kilowatt hours of electricity, 3000 gallons of water and keeps 30 lbs of air pollution out of the air (these statistics provided by our secure paper handling company who partners with a recycling company).

Theresa M. Clarke
Vice President
ShoreBank
7936 S. Cottage Grove
Chicago, Il. 60619
Phone: 773-420-5452
Fax: 773-420-5453