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FDIC Federal Register Citations

via e-mail

BAY STATE SAVINGS BANK

From: Pam LeBlanc [mailto:pleblanc@baystatesavings.com]
Sent: Tuesday, March 02, 2004 4:02 PM
To: Comments
Subject: Alternative Forms of Privacy Notices

Thank you for the opportunity to provide comments relative to the Interagency Proposal to Consider Alternative Forms of Privacy Notices Under the Gramm-Leach-Bliley Act.

Bay State Savings Bank is a 6 branch, $245 million dollar local community Bank with approximately 28,000 customers. We are currently required to provide a Privacy notice to all new customers when they establish an account with the Bank. We are also required to send an annual mailing of our privacy practices to all customers. The Bank utilizes a simple notice detailing the information we collect and that we may disclose the information within the exceptions. We do not disclose outside of these exceptions, therefore no opt-out is provided. We do not feel it makes sense from a cost perspective for a Bank to be required to maintain a short form of its privacy practices and also be required to print and store a longer, more detailed version for those who request it. The basic cost to us of providing an initial privacy notice is $.13 per notice and with an average of 300 new accounts opened and 100 loans established each month. This results in an annual cost of $624.00 to provide the initial notice to customers, which we consider to be a reasonable cost. This cost would increase considerably if we were required to print and have on hand an inventory of long form notices just in case we’re asked for it. Since the privacy rules went into affect, we have had no comments/complaints from our customers indicating that they did not understand our notices nor have we had any questions relating to our current practices and disclosure.

For the required annual notice, as stated above, with a customer base of 28,000 customers, the cost of printing a sufficient supply of privacy notices is $3,640.00 plus the cost of postage of $10,360.00, makes the cost increase considerably (Annual cost of $14,000.00). We are of the opinion that it does not make sense to continue to mail the annual notice unless the Bank makes changes, enhancements or revisions to its policy or unless the Bank is required to include an opt-out provision because they share information outside of the exceptions. Our experience tells us that these notices often go ignored and are unread by consumers since they are inundated with so many. As long as a Bank documents any changes to its privacy notice and the date that the revised policy was mailed, if necessary, this should be acceptable to regulators.

Thank you again for the opportunity to comment on this proposal.

Sincerely,

Pamela L. LeBlanc
Assistant Vice President, Compliance Officer
Bay State Savings Bank
Worcester, MA 01608


Last Updated 03/02/2004 regs@fdic.gov

Last Updated: August 4, 2024