From: Wilma van Leeuwen
Sent: Monday, August 23, 2004 11:19 AM
To: Comments
Subject: EGRPRA Burden Reduction
The Gramm-Leach-Bliley Act
of 1999 established requirements to provide privacy notices at the
time of account opening and on an annual basis.
The initial mailing of privacy notices served the purpose of notifying
customers of a financial institution’s privacy policy. A privacy
notice is provided to each new deposit, loan, and other financial
services customer at time of account opening and is posted in each
institution’s branch offices. After an institution has provided
an initial privacy policy notice, unless the policy changes, it seems
impracticable to provide that same policy annually. The rule could
be more meaningful and efficient if the notices are send only if
the policy changed. For small institutions, under $1 billion in assets,
that do not share customer information, this is an especially costly
and non-productive exercise that adds to the institution’s
regulatory burden and paper work.
Wilma van Leeuwen
Vice President/Compliance Officer
First City Bank