FDIC Federal Register Citations

EMPRISE BANK

July 22, 2004 


Robert Feldman 
Executive Secretary 
Federal Deposit Insurance Corporation
550 17th Street NW 
Washington, DC 20429

Re: Comment Regarding FACT Act Disposal Rule 

To Whom It May Concern:

After reviewing the proposed rules for the disposal of consumer information it appears this is a lot of additional paper work for something which has already been covered in the Gramm-Leach-Bliley Act Safeguards Rule. While there may be other entities that need this regulation to insure proper disposal of consumer information banks have an Information Security program in place that addresses the disposal of customer information.

Since we already have an Information Security program in place that addresses the disposal of "customer information," modifying our program and policies so that we address the disposal of "consumer information" is an unnecessary step given the fact that the definitions of "consumer information" and "customer information" overlap.

Modifying our program and policies to address the disposal of "consumer information" is unnecessary because the definitions of "consumer information" and "customer information" overlap.

Respectfully submitted, 
Diana Fisher 
Executive Vice President