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From: George Staiti
Robert E. Fieldman, Executive Secretary
RE; Model Privacy Form
Dear Mr. Feldman:
I appreciate the opportunity to comment on the Interagency Proposal for Model Privacy Form Under the Gramm-Leach-Bliley Act. This Interagency Propsal is directed by Section 728 of the Regulatory Relief Act.
I find the Model Privacy Notice to be adequate in format.
However, I find the form cumbersome, for delivery purposes. The form should be designed to fit on the front and back of one page, rather than using multiple pages, and provide space for a financial institutions logo. Multiple pages become costly to small institutions like mine.
The requirement to provide annual notice should be eliminated, and perhaps replaced with the requirement for an initial notice at account opening, then again only if an institution changes its policy, and upon request by a consumer. For small institutions like mine, this annual mailing is both costly and time-consuming. This is the only notice requiring annual delivery to customers and is a prime candidate for regulatory relief.
George P. Staiti
|Last Updated 05/09/2007||Regs@fdic.gov|