FDIC Federal Register Citations

August 2, 2004

Robert E. Feldman
Executive Secretary
ATTN: Comments/Executive Secretary Section
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429

Dear Executive Secretary:

Thank you for the opportunity to comment on the notice of proposed rule making regarding affiliate marketing opt-outs. I represent a small bank of about $175 million
in assets located in a rural community.

I do not believe that information sharing should be limited between wholly owned affiliates. This just may encourage consolidation of affiliated organizations.

I see no consumer benefit resulting from requiring opt-out or opt-in notices for sharing of consumer information between wholly owned affiliates of banks.

I believe the existing laws provide ample consumer protection. I feel further limitations on information sharing only hinders the exposure of new product offerings to the consumer.

Therefore, I believe there should be no change in regulation of information sharing between affiliates. We believe that part 334 of the FDIC’s Rules and Regulations “Notice of Proposed Rule Making Regarding Affiliate Marketing Opt-outs” should not be adopted.

If you have any questions please give me a call.

Sincerely,

James K. Caldwell
President