|Sent: Monday, March 13, 2000 9:44 AM
As a private security consultant and investigator, I am concerned about the negative consequences if in the provisions of the Gramm-Leach-Biley Act of 1999; Privacy Rule "non public personal information" is defined to include simple names and addresses of customers of financial institutions. Critically important tools for locating witnesses and suspects will be unnecessarily blunted with very little benefit to the general public. It was my impression that the clear intent of Congress was to provide 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 financial institutions is defined as "non-public personal information". then what is "public"? Congress was offering a distinction by describing financial information. I believe the Act provides opt-out of information regarding credit history, employment, and financial assets. However, name, address and telephone number should not be classified as "non-public". If this information is deemed "non-public personal" , only wrongdoers and criminals will benefit and the law abiding consumer will be the losers. We utilize this information to investigate fraud, embezzlement, locate child support debtors, stalkers and scam artists. Current address information is important for private investigations since law enforcement seldom has the manpower to develop these cases for prosecution. For the above mentioned reasons, I urge you to define non-public personal information in the manner that Congress intended.
Very truly yours,
Brian R. Hollstein,