FDIC Federal Register Citations

Reading Co-operative Bank

From: Thurlow, Julie
Sent: Wednesday, March 21, 2007 1:54 PM
To: Comments
Subject: Model Privacy Form

Dear Mr. Feldman,

We are in receipt of your 189 page report seeking comment on the establishment of a federal format for the annual privacy notices to replace the notices each bank developed based on the GLBA.   Our Annual Privacy Notice process has been in place for a number of years without criticism.  Our bank does not share information. The new and improved Federal Form does not provide any additional information for consumers then the existing form developed and issued each year by the bank.

I am amazed that such resources were expended by our regulator on this simple notice.  Each member bank, regardless of size is now required to read this 189 dissertation to determine the impact on its operations.  There is no consumer benefit at the end of the day; this is just another statement stuffer or marketing letter that gets dismissed when opening the mail.

The impact on our bank is as follows: 

·         We will be required to destroy existing supplies of our Deposit Account Agreements where our perfectly compliant Privacy Statement exists

·         Destroy our current stock of annual privacy notices

·         Expend marketing dollars on the design and production of new account agreements and notices.   

I am aware that we are not required to change our notice, however, if we do not comply and choose to continue with our existing stock of forms, we will not be afforded the safe harbor provisions.  If our existing forms are compliant based on numerous state and federal examinations, why should they not benefit from the safe harbor provisions?

Finally, this design change was first discussed in conjunction with alleviating the annual requirement for this notice as long as the financial institution did not change its practices and was not sharing information.  If that were a consideration then the long term savings of print, production and mailing costs would offset the costs referenced above.

I do not support this change, as I believe it is needless at this time and will require the wasting of human and monetary resources without reason.  There is no consumer or financial institution benefit from this change

Julieann M. Thurlow
President and CEO
Reading Co-operative Bank
180 Haven Street
Reading, MA 01867