Thayer County Bank
From: pkenner@thayercountybank.com [mailto:pkenner@thayercountybank.com]
Sent: Wednesday, June 23, 2004 1:44 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov; regs.comments@ots.treas.gov
Subject: EGRPRA I would recommend both to Congressional representatives and to regulators
that a test marketing be done on proposed regulations to better insure that
the intent of the regulation and effort is being served effectively. I
believe I was told through FDIC sources that they may be considering market
testing revisions of the Privacy Act Notice. I fully support this
methodology and believe that it should be used for all regulations. I fear that the consumer that we as government leaders are attempting to
protect through disclosures are note effectively being reached through the
volumes of fine print and complex disclosures that we are required to
provide. Closing a home mortgage today is overwhelming for a college PhD
let alone a hard working blue collar worker that is not as apt to read
volumes of fine print. Once a consumer attempts to read the first few
pages of an advance disclosure I believe they often times throw up their
arms in distress and accept what is in front of them. Market testing
disclosures would be a great method of measuring various ways of getting
the information to the consumer. If one recalls what the financial
industry did to provide banker's with disclosure information on investment
security "stress test", the industry developed some nice graphic thumbs up
and thumbs down and some other little graphs that depicted cash flow
duration. I would venture to say that many investors came to accept the
thumbs up and thumbs down much better than reviewing the volumes of
financial disclosure statements and yield tables that came along with the
investment purchases. With regard to Reg Z and mortgage disclosures,
perhaps a simple graphic that would show the consumer their APR relative to
current secondary market indexes on a certain date would be an easy way to
illustrate if they are getting a competitive mortgage product. With regard
to Privacy perhaps a simple sign such as a green light, yellow light, red
light, would be an indicator to consumers that there is no sharing, there
is sharing between affiliates, or there is open sharing of information.
There could be one simple format issued to accompany the symbol that would
be uniform among all agencies, businesses and disclosing parties.
Consumers would have an easy and uniformly understood indicator of the
security of their personal information when dealing with that entity.
Our government has implemented standards of agencies that require them to
compute the time it takes to complete a government form. Perhaps there
should be a mandate on Congress as well as on the regulators that they be
required to develop regulations which require at least a 50% (or some
acceptable percentage) effectiveness of an implemented regulation with
regard to the intended purpose of the law. We need to address the question
" Will 50% of an average consumer group understand the disclosure when
presented to them as required by the proposed law?". If and when we fall
short in this regard we are simply imposing a cost, which eventually falls
upon the consumer, for a very ineffective mandate.
Patrick W. Kenner
President, Thayer County Bank
402 Lincoln Avenue
Hebron, NE 68370-0109
Mayor, City of Hebron
216 Lincoln Avenue
P.O. Box 29
Hebron, NE 68370 | 
