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Iowa State Bank and Trust Company
From: Marcia McKeag [mailto:MMckeag@isbt.com]
May 22, 2007
Re: Interagency Proposal for Model Privacy Form under the Gramm-Leach-Bliley Act
Thank you for the opportunity to comment on the Proposed Model Privacy Form. Iowa State Bank & Trust Company is a state chartered community bank staffed by consumers. As consumers we are personally affected by the privacy regulations in addition to our roles at the bank, which includes delivering and explaining the bank's privacy and information sharing practices to other consumers.
The proposed model form is professional looking, informative and more reader friendly than current prose formats used by many financial institutions. Also, the proposed form makes it much easier for the consumer to determine if they can choose to limit sharing of their information and what actions they need to take to opt-out.
We like the idea of a standardized format, both as a bank and as consumers. Similar to standard nutritional information on food products, we think the standardized privacy form will be much more effective for consumers to understand and compare privacy practices between financial institutions. As consumers, we will know where to look for a specific answer as compared to privacy notices today where we usually need to wade through a wordy document, which sometimes, we don't ever find the answer we were looking for.
Currently, Iowa State Bank posts its privacy notice on our website as well as delivers a paper notice. In 2006, we modified our privacy notice adding specific verbiage related to online privacy and security including what information is collected or stored by visiting our website and the security of information sent by email or the bank's secure electronic portal. The proposed Model Privacy Form does not have any such language and we suggest it be added.
We are opposed to printing each page separately rather than front-to-back. In an effort to preserve the environment we live in, eco-friendly approaches should be emphasized. Requiring single-sided printing does just the opposite by using double the amount of paper and energy to produce the paper notice. Further, we think it would be more beneficial to give the notice when a consumer initially establishes a new product or service then thereafter only when the bank's practices change or upon consumer request. This could be stated in the first box under Sharing Practice, 'How often does ABC Bank notify me about their practices?' This would further preserve paper and energy. In the study, one of the meta-theme! s was to "Keep it simple" further stating "Our evolution of the prototype focused on minimizing burden on the consumer by continually simplifying the notice. We stripped away redundancies, reduced words, used simpler words, clarified meaning and provided key context information up front." Providing the notice initially and when practices change keeps with this theme.
We use platform software to generate deposit and loan account-opening documentation including the privacy notice. Unless the vendor makes programming changes, the proposed table layout will be challenging for us to create in our consumer loan software. Alternatively, a benefit of a model privacy form is that the vendor could add the form as a standard document with text options or fields for sharing practices.
At this time we do not share with affiliates, but if we did it is likely we would incorporate the FCRA section 624 disclosure and opt-out into the model form. We think having both sharing practices and opt-outs in one form would be easier for consumers to comprehend.
Again, we appreciate the opportunity to comment on the model privacy form and consideration given by regulatory agencies.
|Last Updated 05/23/2007