Sent: Monday, March 13, 2000 2:11 PM

RE: Docket No. 2000.13

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 licensed  private investigator and small business person, I fear we would lose a  valuable and very necessary source of locating witnesses and suspects 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"?  Congress seemed to be offering a distinction by describing financial  information. 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."

Private investigators play an important role in our civil and criminal  justice systems which is not understood by many. The information we obtain  regarding addresses and phone numbers is essential to our conduct of business  and fulfilling our obligations to consumers. We utilize this information  to investigate embezzlement, insurance fraud, locate delinquent child support  debtors and serve process among other things. Stalkers and scam artists  seldom reside where their vehicles are registered so current address  information is essential and law enforcement seldom has the manpower to  develop these cases for prosecution.

If this information is deemed "non-public personal," only wrongdoers and   criminals will benefit and the law-abiding consumer will be the loser. I  urge you to define non-public personal information in the manner that  Congress intended.

Yours truly,

Doris Hebert-Ferrigno
President
National Research Group