From: Nancy Rich
Sent: Monday, August 16, 2004 12:11 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
Subject: Recommendations Sought to Reduce Regulatory Burden From
Certain Consumer Protections Regulations.
I would like to respond to section II. E. concerning the reporting,
recordkeeping and disclosure requirements. The Gramm Leach Bliley
act requires an annual disclosure to all account holders explaining
an institutions’ Privacy Policy. This seems unduly necessary
since a copy of the Privacy Policy is given to a customer when
an account is open. What an institution must spend on the mailing
of this disclosure can be very time consuming and quite expensive
especially when an institution does not even share any information.
In fact, the general population is so over whelmed by all the junk
mail received that few even read the disclosure. And many of those
do not understand what they are reading. Daily we received phone
calls from customers saying they wanted to opt out. At that time
we did not share their personal financial information, but we had
to answer each question and explain that opting out was not an
option. Today, I agree that since our institution now shares personal
financial information, we should continue to mail a copy of our
Privacy Policy on an annual basis. But for those institutions that
do not share, I feel that the annual disclosure should be eliminated.
Nancy Rich
Gwinnett Community Bank
Vice President Operations