CAPITAL CITY BANK
From: Staalenburg, LeAnne
Sent: Monday, August 30, 2004 11:34 AM
To: Comments
Cc: Hutchison, John
Subject: GLBA / EGRPRA Burden Reduction Comment Letter
Importance: High
To Whom It May Concern:
The Gramm-Leach-Bliley Act of 1999 established requirements to provide
privacy notices at the time of account opening and on an annual basis.
The
initial mailing of privacy notices (prior to July 1, 2001) served
the
purpose of notifying consumer customers of a financial institution's
privacy
policy. After that date, a privacy notice is provided to each new
deposit,
loan, and other financial services consumer customer at time of account
opening and is posted in each institution's branch offices. The initial
notice is important to consumers because it informs them about the
way their
institution handles their non-public personal financial information.
Currently, GLBA requires a financial institution to annually provide
their
privacy policy notice to consumer customers. At our bank, we have
found
clients complaining about getting these notices each year. We send
the
majority of these notices as statement stuffers, but there is a segment
of
our consumer customer base who do not annually receive a statement.
For
those customers, we must do a direct mail to get them the privacy
notice.
The annual notice requirement is an especially costly (in printing,
postage
and man hours) and non-productive exercise that adds to the institution's
regulatory burden and provides the customer with no new information.
After an institution has provided an initial privacy policy notice,
unless
the policy changes, it seems impracticable to provide that same policy
annually. The GLBA notice requirements would be much more meaningful
to the
customer and efficient and cost effective to the financial institution
if
the notices are sent only if the institution's privacy policy changed.
If
notices are mailed annually (even with no policy change), consumer
customers
will be less likely to read and notice when the policy has been revised.
If
a customer gets a privacy notice each year, he/she might not notice
if their
institution (who initially was not subject to the opt-out provision)
changed
their policy where opt-out would apply.
Thank you for allowing me the opportunity to comment.
LeAnne Bailey Staalenburg, CRCM
Assistant Vice President
Compliance Privacy & Training
Capital City Bank
P O Box 900
Tallahassee, FL 32302
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