This response to the Interagency Proposal to Consider Alternative
Forms of Privacy Notices Under the Gramm-Leach Bliley Act is an
individual's endorsement of the effort to simplify and standardize
privacy notice disclosures. I agree this will improve customer
understanding and facilitate policy comparisons between institutions. I
agree with the basic premise that one of the primary purposes of the GLB
Act was to restrict the sharing and release of personal customer
information and data. Although this is a complicated issue with many
considerations, I support the Agencies effort to pursue the development
of a short privacy notice. As it stands today, the ordinary consumer
finds it difficult, if not impossible, to make heads or tails of
information in the complex and lengthy privacy disclosures from any
bank. I believe there is a benefit from sharing customer data within a
financial services company and its affiliates. It is many times this
proactive approach that opens the door to consumer savings, better
services or alternative products. This might not be the case with third
parties. A short notice with a specific format and standardized language
(such as that suggested in Appendix A, including instructions on how to
obtain a copy of the complete Privacy Notice) would help consumers to
compare this information between financial providers. Other possible
methods suggested in the RFC might be improvements over the current
situation, but would be more complicated and may still not achieve the
desired end result. In any case, a short notice would be beneficial to
consumers because it would have a chance of not only being read, but
also understood. Although there is not much difference in the cost to
produce either option, the benefits of a short policy would be
significant readability improvement for consumers. A single sheet
disclosure (where a grid or miniature type) would cost substantially the
same amount to print or distribute. I liked the option proposed in
Appendix A as a possible format and encourage the Agencies to adopt a
mandatory application with standardized language. In this case, only the
short notice would be required distribution, with the full disclosure
version and an opt-out connection (for both internal and external
information sharing) being offered to consumers in an easy to access
format embedded (or noted) in the short notice. Thank you for the
opportunity to comment on this important and timely issue.
