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WALWORTH
STATE BANK
March 17, 2004
Mr. Robert Feldman, Executive Secretary
Att: Comments/Executive Secretary Section
FDIC
550 17th Street
Washington DC 20429
RE: ANPR Regarding Privacy
Dear Mr. Feldman:
We are a small ($160MM) independent community bank serving a rural,
tourist area in Southern Wisconsin. We purchase our privacy notices from
a vendor, there are several to choose from, who will be sure to comply
with whatever you require.
My main concern is the notification requirements. I see no problem
with the initial notification requirements. I do believe the subsequent
annual notification is overkill, not cost effective, and an unnecessary
burden on financial institutions.
It makes no sense to me to continually send an annual notice to all
customers unless something has changed in the institutions privacy
policy. I would suggest requiring the privacy notice posted in all of
the financial institutions locations just as we are required to post our
CRA & Funds Availability Policies and our Equal Housing Lender Logo. In
addition the policy is required on the bank web site. Then require the
policy to be mailed to any customer upon their request.
To annually send a notice is too expensive and burdensome to keep
track of. A loan or CD customer may not have another account that gets
regular mailings (statements) and the coordination to get the notice to
all without just mailing the separate piece is burdensome and expensive.
My own experience with notices I receive from insurance companies, etc.
is that I just throw them away. If I had a question I would resolve it
on my initial contact and then forget it. I find subsequent notification
a nuisance If I have a question I find out right away by requesting the
information and not waiting until I would get the annual privacy notice.
I believe you would do the same.
Therefore relax the subsequent notification requirement with the
procedures above.
Sincerely,
Tobias J. Steivang
CEO/Chairman
Walworth State Bank
Walworth, WI
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