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FDIC Federal Register Citations

Hometown Bank

From: Stephen J Mills
Sent: Tuesday, May 08, 2007 9:44 AM
To: Comments
Cc: Mike Bahrs; Lynn Wehner; Jim Voight; Robb Kahl
Subject: Model Privacy Form

To Whom It May Concern:

Pursuant to your request for comments regarding the proposed Model Privacy Notice by May 29, 2007 please find the following:

After reviewing the Interagency Proposal we have found the Model Privacy Notice to be an improvement over prior guidance provided by the Agencies. We believe the Model Privacy Notice would enable consumers to more easily identify and compare sharing practices among financial institutions. However, we believe the form should be designed to fit on the front and back of one page, rather than using multiple pages.

The privacy rule requires a financial institution to provide a privacy notice to its customers no later than when a customer relationship is formed and annually for as long as the relationship exists.

The requirement of providing a notice to customers annually, regardless of whether or not a financial institution’s practices have changed, should be the primary subject of regulatory relief. This requirement is unique to the privacy notice. The cost of an annual mailing of privacy notices is excessive and wasteful, and receipt of the notice is often an annoyance to consumers.  Additionally, with the receipt of privacy notices from a multitude of different companies and institutions, it is probable that these notices are discarded without having been reviewed by customers, based on responses from previous annual mailings.

A more reasonable requirement to delivering the privacy notice, consistent with other regulatory notice requirements would be to:

-- Provide a notice to the customer no later than when a customer relationship is formed;

-- Provide a notice to the customer whenever there is a change in the financial institution’s
   privacy practices; and

-- Provide a notice upon a consumer’s request.

In summary, we believe the proposed Model Privacy Notice (with minor format changes) is an improvement. However, financial institutions and consumers would be better served, and regulatory relief would be advanced if the annual mailings were no longer required.

Respectfully Submitted,

Stephen Mills

VP Hometown Bank

Fond du Lac, Wisconsin


Last Updated 05/08/2007

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