From: Doug Feldhake
Sent: Wednesday, August 04, 2004 2:55 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
GLBA – PRIVACY DISCLOSURES
- 12 CFR Part 332
I would like to see the requirement for mailing annual privacy
notices be repealed and replaced with a lobby notice. The cost
of printing and mailing annual notices to all bank customers is
burdensome. It my opinion and my personal experience that the privacy
notices are not being read by customers. We are an $80,000,000
institution and spend over $3,000 annually providing privacy notices.
Sales of Insurance – 12 CFR Part 343
If a bank does not have an insurance subsidiary and the only insurance
products that are sold are Credit Life and Disability, I think
the only disclosure that should be necessary is the customer signing
on the Loan Contract indicating they are purchasing the insurance
product and showing what the premium is. If we do not sell Credit
Life or Disability insurance to the customer I do not believe we
should be required to provide an insurance disclosure. It may be
to the bank’s benefit to have the customer sign something
saying they do not want to purchase Credit Life or Disability Insurance,
but I do not believe a disclosure saying that as a condition of
granting the customer a loan, the lender cannot require that they
purchase an insurance product and that the lender cannot require
their agreement not to obtain or prohibit the customer from obtaining
an insurance product from someone else, provides any benefit to
our customers.
The portion of the regulation requiring disclosure of the possible
sale of insurance AT APPLICATION should be deleted and the only
disclosure should be required is when the customer is purchasing
an insurance product and their signature acknowledging such should
purchase and the premiums involved should suffice.
Sincerely,
Doug Feldhake
Vice President/Compliance Officer
Crossroads Bank, Effingham, IL