Fri, Mar 24, 2000 8:58 PM
TO WHOM IT MAY CONCERN:
I am writing to express my concern with the proposed regulations to implement Title V of the Gramm-Leach-Bliley Act of 1999. As a business professional and small business owner, I fear we would lose a valuable and very necessary source of locating individuals if "non-public personal information" is defined to include simple names and addresses of customers of financial institutions.
It was my impression that the clear intent of Congress was to provide an opportunity for customers of financial institutions to "opt-out" of sharing their personal financial information with non-affiliates of the institutions. The statute provides protection for financial information-not mere names and addresses. If all information available to a financial institution is defined as "non-public personal information", then what is "public"? I believe the Act provides opt-out of information regarding credit history, employment and financial assets but name, address and phone number should not be classified as non-public.
Credit bureaus have the most current name and address files available because consumers update their addresses with their credit card companies and other lenders when they move. The information has the following uses:
Prior to the use of "header data" from consumer reporting agencies, the best available source of names and addresses was the telephone directory. If Regulation P prohibits the use of header data, the above mentioned will be forced to return to the phone book for names and addresses.
If this information is deemed "non-public personal", only wrongdoers and criminals will benefit and the law-abiding consumer will the loser. I urge you to define non-public personal information in the manner that Congress intended.
Cecelia R. Gallentine