Texas Bank
and Trust
March 26, 2004
Robert E. Feldman, Executive Secretary
Attn: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
550 17th Street NW
Washington DC 20429
Re: 12 CRF Part 332
RIN 3064-AC77
Dear Mr. Feldman:
Texas Bank and Trust is a $550,000,000 independent state bank with
nine branches located in northeastern Texas. We appreciate the opportunity
to comment on the proposed amendment to sections 502 and 503 of the
Gramm-Leach-Bliley Act. It is helpful for regulatory issues to be
explained in plain language. We applaud your efforts to provide alternative
language for privacy notices, making them more easily understandable
to consumers.
However, for
banks like ours who do not share any personal information for marketing
purposes,
the requirement to send an annual disclosure
seems redundant. Since there is no need for them to opt-out, customers
are often confused by the repeated notices, or they pay little, if
any attention to them. It would seem more effective to provide an
initial disclosure, with additional disclosures to follow only if
our privacy policy changes. Contact information regarding privacy
issues could be printed on statements for the customer’s convenience
in requesting additional information.
If a workable, standardized initial notice could be produced, it
should enable the customer to:
- readily determine
how the institution intends to use their information,
- easily exercise their rights to opt-out,
- compare the policies of one institution to those of another.
As a state-chartered bank, we are also required to provide information
about how to file a complaint with the Texas Department of Banking,
to be included with our privacy disclosures.
Due to the time and expense required to reformat notices and update
platform systems, changing to a standardized notice should be voluntary
for at least three years. If a mandatory procedure were adopted requiring
all financial institutions to use these notices, the delay would
allow for existing
inventories of printed materials to be exhausted.
The majority of our disclosures are enclosed with regular statements.
We spent approximately $5,000 in 2003 for additional postage and
printing to mail annual notices to those customers who do not receive
regular statements.
We agree that a standardized, more user-friendly privacy notice
would benefit consumers. We request that a sufficient time-frame
be allowed to comply with any regulatory changes, and suggest that
annual disclosures be discontinued for financial institutions who
do not share private information. Thank you for your attempts to
make the GLB Act more effective, and for considering our comments.
Sincerely,
Kathie Sims
Privacy Officer
Assistant Vice President
Texas Bank and Trust
(903) 237-5698
ksims@texasbankandtrust.com
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