Skip Header

Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations




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


Last Updated 03/31/2004 regs@fdic.gov

Skip Footer back to content