|Sent: Sunday, March 12, 2000 11:13
To Whom IT May Concern:
I am writing to express my concern with the proposed regulations to implement Title V of the Gramm-Leach-Bailey Act of 1999. As a Judicial Judgment Recovery Specialist and small business pereson, 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 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".
Judgment Specialists play an important role in our civil justice system which is not understood by many. The information we obtain regarding addresses and phone numbers is essential for us to conduct business and fulfill our obligations to consumers. We utilize this information to locate delinquent judgment and child support debtors among other things. Judgment debtors rarely stay in one place for long and the utilization of credit headers with the address and phone number information they provide, is vital to locate these debtors and serve justice.
If this information is deemed "non-public personal", only wrong doers and criminals will benefit. The law abiding consumer will be the loser. I sincerely urge you to define non-public personal information in the manner that Congress intended.