From: George Staiti
Sent: Tuesday, May 08, 2007 4:02 PM
Subject: Model Privacy Form - RIN 3064-AD16
40 Main Street
Ware, MA 01082-0849
Robert E. Fieldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE; Model Privacy Form
Dear Mr. Feldman:
I appreciate the opportunity to comment on the Interagency Proposal for
Model Privacy Form Under the Gramm-Leach-Bliley Act. This Interagency
Propsal is directed by Section 728 of the Regulatory Relief Act.
I find the Model Privacy Notice to be adequate in format.
However, I find the form cumbersome, for delivery purposes. The form
should be designed to fit on the front and back of one page, rather than
using multiple pages, and provide space for a financial institution’s logo.
Multiple pages become costly to small institutions like mine.
The requirement to provide annual notice should be eliminated, and
perhaps replaced with the requirement for an initial notice at account
opening, then again only if an institution changes its policy, and upon
request by a consumer. For small institutions like mine, this annual mailing
is both costly and time-consuming. This is the only notice requiring annual
delivery to customers and is a prime candidate for regulatory relief.
George P. Staiti
Assistant Vice President