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FDIC Federal Register Citations

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MIDWESTONE BANK & TRUST

From: Steve Hicks
Sent: Friday, January 30, 2004 4:14 PM
To: Comments
Subject: Privacy Notices

January 30, 2004

To Whom it May Concern:

I am responding to the public comment period currently open to the public under the Gramm-Leach-Bliley Act as it pertains to annual privacy notices.

An annual privacy notice requirement has put an undue burden on all companies required to provide this document on an annual basis. This burden comes in the form of excess labor, materials, and postage costs. The only people winning under the current regulation are commercial printers and the U.S. Postal Service. No one else.

My suggestion, would be the following;
Require an initial privacy notice to a new client of the institution to be provided at the time the initial account or relationship is opened. From that point forward, the only additional requirement would be if the institution makes any material changes in it's policy in sharing information; in essence, changing from the initial policy provided to the consumer. At that point, a new privacy policy would be sent to all customers notifying them of the change.

With all due respect, the current regulation is inadequate. Our estimates are that a very small percentage of consumers who receive such a voluminous document in the mail, actually read, let alone open, the document. Those that do open the document, find little relevance as to its content. At a minimum, I suggest an inexpensive (straw poll) survey be completed of consumers to see what impact, if any, these mailings are having. Only then, can an educated decision be made based on actual facts. Why have regulations that only burden companies and confuse the public.

Thank you for you time and support.

Steven P. Hicks
Executive Vice President
MidWestOne Bank & Trust
124 South First Street
Oskaloosa, IA 52577
Phone: (641) 673-1552
Fax: (641) 673-1523
e-mail: steveh@mwofg.com
 

Last Updated 02/02/2004 regs@fdic.gov

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