|Received:||5/3/2007 3:08:06 PM|
|Agency:||Federal Trade Commission|
|Rule:||Interagency Proposal for Model Privacy Form under the Gramm-Leach-Bliley Act|
Comments:While I commend the agencies for drafting simpler language for privacy notices, I urge the FTC to re-think the concept of 3 separate forms. This will add to an already excessive compliance burden for banks. Most banks provide the annual privacy notice as a statement stuffer in statements that already must be sent to customers. Adding 2 or 3 8 1/2 X 11 sheets of paper is much too costly and unworkable as a statement stuffer. There is little rationale to prohibiting a 2-sided notice other than consumers prefer two separate sheets. Regulations must balance the interest of consumers with the cost associated with businesses providing services to those consumers. Simply notifying the consumer that there are additional disclosures on the back of a 2-sided form seems reasonable. In fact, I would urge you to re-design the form to include everything on one 2-sided form including opt out. It would appear there would be plenty of room if the space was used more efficiently. Thank you for your consideration and applying common sense. Let's find a way to reduce the burden on banks and to save the cost to consumers (yes .... banks will pass along these costs) and protect the environment by not creating one or two more unnecessary pieces of paper that at best will be recycled and at worse will end up in a landfill.