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CITYWIDE BANKS
From: Bonnie MINEO
[mailto:MINEO@citywidebanks.com]
Sent: Tuesday, March 16, 2004 12:22 PM
To: Comments
Subject: ANPR Regarding Privacy
Consumers have been inundated with privacy notices since the Privacy
regulation went into effect. Looking at it from a consumer perspective
based on the numerous notices I have personally received at home, most
are very lengthy, in very small print, and take an excessive amount of
time to actually read.
I believe the best approach would be to simplify the notice for both
the consumer and the financial institution. A short notice with a
specific format and standardized language that would be designed to
address all of the relevant elements listed in the GLB Act and the
privacy rule without providing for an additional longer version of the
notice would be much less confusing to the consumer and the financial
institution. Maintaining and providing a short notice but tracking
requests for and providing a longer notice on request would place an
additional unnecessary burden on the financial institution.
If a short notice is approved, it should be mandatory for all
institutions in order to ensure that the consumers receive a
standardized format from all institutions. Otherwise, modifying the
existing requirements would not be beneficial.
If use of standardized clauses is not required, a safe harbor should
be created for financial institutions that use standardized parts in
their notices (or a whole standardized notice). Many institutions do not
have an opt-out except for FDRA affiliate sharing and would benefit from
a shorter notice with standardized language.
I prefer the format in Appendix A "without" an additional longer
notice required. It appears to be easier to read and understand.
Respectfully Submitted,
Bonnie MIneo/Compliance Officer
Citywide Banks
10660 E. Colfax Ave
Aurora, CO 80010
303/365-4030
mineo@citywidebanks.com
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