Community Bank of Parkersburg
From: Kim Wolfe Flinn [mailto:kflinn@communitybankpkbg.com]
Sent: Wednesday, April 14, 2004 12:08 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
April 14, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention Comments
Federal Deposit Insurance Corp.
550 – 17th Street, NW
Washington, DC 20429
Re: Reducing Regulatory Burden Lending-Related Consumer Protection Rules
Dear Mr. Feldman:
We are encouraged with your efforts to reduce regulatory burden
on the financial services industry. Community Bank of Parkersburg
strives to fulfill our obligations to all regulations.
The requirement of sending an annual privacy notice to all customers
that accurately reflect the banks privacy policies and practices
not less than annually during the continuation of the customer relationship
( FDIC Part 332.5(a)(1)) is unnecessarily burdensome, redundant and
unnecessarily costly to the financial services industry. The customer
receives the notice at account opening as required and again by mail
if there are changes to the policy, but sending the same notice again
annually is unnecessary. When the regulation was introduced it was
necessary for all current customers to be aware of the written Privacy
Policy by each institution. But now that this policy has been in
place for several years and the customers have received several notices,
the regulatory notification should be satisfied and the annual notice
distribution should be rescinded.
As a small institution, it is very expensive and would be even more
so for larger institutions. This recommendation is then made to end
the redundancy of the Privacy Policy notification. I would be glad
to talk with anyone to further explain the cost of time and materials
necessary to meet this regulatory obligation. I look forward to working
with the FDIC to continue all of our efforts to make the customer
feel confident in the financial services we offer.
Very truly yours,
Kim Wolfe Flinn
Assistant Vice President and Compliance Officer
Community Bank of Parkersburg
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