From: James Marek
Sent: Thursday, March 18, 2004 9:52 AM
To: Comments
Subject: GLBA reform suggestion
Our bank is a small community bank in central Texas that has never
sold or
otherwise provided, customer information to outside entities other
than to
vendors who help us provide bank products to our customers. The added
expense and regulation associated with GLBA is particularly frustrating
since we do not share customer info with anyone outside the bank
yet we
still have to send disclosures to our customers each year telling
them we do
not share their information.
While we understand that the intent (to protect customer information)
of
this legislation was certainly good, it seems that the original purpose
of
the legislation could be enhanced by making one very small amendment
to the
existing law.
My suggestion would be to require only those banks who plan to sell
or
otherwise provide their customers information to outside entities
to send
out an annual disclosure.
This would have two significant benefits
1. Eliminate costly overhead and regulation for the banks that do
not
disclose customer data anyway
2. Raise customer awareness and more succinctly communicate which
financial
institutions were sharing their data. Currently, since all financial
institutions are required to send annual disclosures, the customer
becomes
desensitized to the disclosure and is more likely to discard the
notices
than read them. In other words if only the banks that were selling
the info
were the only ones required to disclose annually, then the consumer
would
know immediately which financial institutions were selling their
data and
could act quickly and more efficiently to stop the activity if they
objected to it.