FDIC Federal Register Citations

THE SCOTTDALE BANK & TRUST COMPANY

February 25, 2004

TO: THE EIGHT FEDERAL REGULATORS SOLICITING COMMENT ON THE IMPROVEMENT OF PRIVACY NOTICES GIVEN TO CONSUMERS UNDER THE GRAMM-LEACH-BLILEY ACT (the GLB Act).

The requirement of Section 503 of the GLB Act is a necessary and important part of the Act. The complexity of the privacy policies of the organizations required to provide privacy notices to consumers should dictate the language in the notice and the frequency in which it should be given.

Our financial institution regards our customer’s privacy with importance. The Scottdale Bank & Trust Company does not share customer information with any other organization outside the permissible purposes. The goal of the privacy notice is to inform the customers of the practices of that organization. This should be a priority of the required notices.

Our experience has been the annual privacy notice mailings confuse our customers instead of the positive results for which the Act was established. The burden to our institution is the annual mailing of the privacy notices. The general considerations for improving the contents of these notices are important, but the frequency of which they are to be mailed should also be a consideration. The cost to print the notices, to process the mailers and the cost of the postage is approximately $10,000.00 annually. This is the cost for a notice that has not changed since the inception of the GLB Act. We recommend that the privacy notice be given to each new customer at the time the new relationship is established, and the only requirement for mailing a subsequent notice would be if any changes have occurred in the institutions privacy policy therefore requiring an updated, notice be mailed.

Sincerely,

Melinda Powell
Compliance Officer
150 Pittsburgh St.
Scottdale, PA  15683