From: David Kreiman
Sent: Thursday, February 12, 2004 2:27 PM
To: CommentsESS
Subject: Comment Regarding Reg P - FIL-8-2004
I was given this e-mail address to
address comments towards FIL-8-2004 - I hope this is the right venue and
procedure. The only real comment I would make would be to propose a way
to reduce the financial burden on banks as it relates to the annual
notice requirement. I have procedures set in place whereby consumers and
customers can receive a copy of our Privacy Policy Statement via our web
site, our branches, and various other delivery channels. All new
customers/accounts are provided the document per the regulations, and
annually, a copy is sent to all of our non-commercial deposit customers.
Up to this point, the process is a nuisance, but not a large expense, as
I can insert the annual notice in their statement fairly easily and
inexpensively. We are a Community Bank, and for the past years, I have
spent close to $10,000 annually to send an annual notice via separate
mail to those customers who do not necessarily receive a routing monthly
mailing (ie: statement). This would include loan customers, safe deposit
customers, etc. To begin with, we do not sell/share nonpublic personal
information. In addition, since creating our Privacy Policy, we have not
changed it, and most likely will not change it, with the exception of if
the regulatory agencies made required changes. For most consumers who
receive annual statements from banks, doctors, and many other
businesses, the notices go unread. I understand that is the case with a
large majority of regulatory paperwork, including warranty information
when someone buys an electronic device. To have to send out the same
notice each and every year is, in my opinion, and unnecessary burden and
expense. I understand the need/requirement if changes are made, and I
understand the need/requirement when a new account is opened. I just do
not see the need for annual disclosures when there are no changes made.
Thank you.
Sincerely,
David M. Kreiman
Sr. VP - Director of Marketing
Privacy Officer
Glenview State Bank
800 Waukegan Road
Glenview IL 60025
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