From: Oak Creek Valley Bank [oakcreek@inebraska.com]
Sent: Friday, April 23, 2004 6:14 PM
To: Comments Subject: privacy
notices
Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance
Corporation
550 17th Street, NW
Washington, DC 20429
ATTN : Comments/Executive Secretary Section
I apologize for the lateness of my comment on Privacy Notices (beyond
the April 16, 2004 deadline), but hope this comment will still be
considered.
Has there been
any discussion or consideration, not to creating a "uniform" or "Model" notice,
but to eliminating the Privacy Notice requirement entirerly - at
least as it relates
to small Community Banks (Under $250 Million for example) who do
not share their information and who have no affiliates.
This entire need for Privacy Notices is driven by the outrageous
action of one Bank that I believe paid dearly for their actions in
negative publicity and other costs. Continuing to heap yet another
requirement on over-burdened and overregulated institutions does
little if anything to help consumers where the information provided
in most all privacy notices is so vanilla and so generic and in most
cases so overly broad that it actually provides little or no useful
information to consumers.
I have personally
received nearly a dozen notices or more from insurance companies;
banks;
brokers; etc. These entities range in size from
very small companies (1 branch/office & a few employees) to Huge
multi-state entities with numerous affiliates/subsidiaries and business
arrangements. Yet, the notices from all of these entities already
look virtually identical. Even though I understand this regulation
and was involved in developing our Bank's policy and notice, I felt
that the notices provided to "me" as a consumer were a
complete waste of time, effort and money which could no doubt be
spent much more wisely given the current world situation. Making
these notices more similar necessary makes them less specific and
less meaningful.
Out of over 1,000
notices sent, our institution received no more than a handful of
comments
from customers all of whom believed we
were doing "more" sharing of their information than we
actually were due to the required language we had to use in the notices.
Given my belief that these notices are thrown away by far more people
than the number who read them I would support eliminating the notices
to the extent permitted and/or extending the time between when they
must be sent. In other words every 3 years or 5 years, not every
year. Clearly a cost/benefit analysis needs done on Privacy and I
DO NOT BELIEVE THE HIGH COST IS WARRANTED BY THE VERY MINIMAL BENEFIT.
Sincerely,
Mark Blazek
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