March 31, 2000
Secretary of Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, NW
Washington, DC 20580
RE: Comment On Proposed Privacy Rule VIA email: GLBRule@ftc.gov
To Whom It May Concern:
Nationwide Home Mortgage Company is writing to express our concern about the strict
requirements of the proposed Gramm-Leach-Bliley Privacy Act (GLB-Act). The proposed
GLB-Act disclosure requirements will increase our cost to service and hinders our ability
to general ancillary income. This increased cost ultimately will be passed on to the
consumer in the form of higher mortgage interest rates and fees.
Other specific concerns include:
Numerous states have proposed rules that would require an "Opt-In" option if
passed. This rule does not pre-empt state laws that provide greater protection than are
provided by the GLB-Act. Monitoring and maintaining separate requirements for each state
is difficult to manage and to ensure compliance. We would prefer federal law prevail over
state law.
We support Alternative B. If the information we choose to supply to a third party
(after providing appropriate disclosures to customer) could be obtained from a public
source, we should be allowed to use our information, rather than obtain it from the public
source.
Will the final act provide a recommended format/verbiage for the disclosures? To ensure
conformity within the industry a recommended format is preferable.
The GLB-Act would require a financial institution to provide an initial disclosure to
consumers who are already their customer on the effective date of the Act no later than 30
days after the rule’s effective date. We recommend this period be extended to at
least 60 days, to allow financial institutions the opportunity to provide the initial
disclosure to existing customers along with end of year statements.
We appreciate the opportunity to comment on this Act. If you care to discuss this
further, please contact me at 515-224-7179.
Sincerely,
Deborah L. Iglehart
Associate Vice President