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FDIC Federal Register Citations To: Comments Subject: EGRPRA Burden Reduction Comment; OCC Docket 0418; Fed Docket R-1206; OTS 2004-35 Comments to FDIC Dear Comments to FDIC: As a community banker, I support the EGRPRA project and commend the banking agencies for their efforts to identify outdated, unnecessary, or unduly burdensome regulatory requirements. I have the following comments concerning the regulations that are currently being reviewed and are categorized as Consumer Protection: Account/Deposit Relationships and Miscellaneous Consumer Rules. Privacy of Consumer Financial Information The annual privacy notice that banks must send to
customers is not only
very burdensome and costly but the language for the
notices required bylaw and regulations is confusing to customers. An
optional short form
notice would be welcome, but it should replace - not
supplement - the existing notice. Since we have already developed
processes and procedures to comply with existing requirements, use of a short
form notice should be
at the bank's option.
Even more important, we should not have to send out
an annual notice if we
do not change our privacy policies and procedures. We
give our customers
the notice at account opening. That should be enough,
especially since we
are happy to provide information about our privacy
policy upon request.
The annual notice is particularly unnecessary for
community banks that share information only as permitted by one of the
statutory or regulatory
exceptions. |
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Last Updated 05/09/2005 | Regs@fdic.gov |