"David B. Johnson" <firstname.lastname@example.org>
Date: Fri, Mar 24, 2000 10:14 PM
Subject: Re: Gramm-Leach-Bliley Act Privacy Rule (16 CFR Part 313 -Comment), Re: Docket No. 2000.13, RE: Docket No. R-1058
Any organization that uses consumer information to conduct business knows that regulatory and legislative scrutiny is at an all time high. This environment has given rise to a situation that demands a swift and comprehensive reaction from all businesses that rely on accessible, accurate, and publicly available consumer information.
The Financial Modernization Act (FMA) is intended to protect consumer interests regarding the use of personal financial information and many companies, including W.D.I.A. Corporation, applaud the objectives of the act, however, something has gone awry.
The Federal Reserve Board of Governors, The Federal Deposit Insurance Corporation, Department of the Treasury, Office of Thrift Supervision, Comptroller of the Currency, and Federal Trade Commission have wrongly interpreted the intent and scope of the FMA as passed by Congress. And that distortion has the potential to seriously disrupt the contributions that the consumer credit infrastructure makes to the overall economy, not to mention your particular business. While logic, overall benefits to the economy, and the interests of consumers would seem to provide a powerful impetus for the regulatory agencies to avoid broad stroke interpretations, to date they are heading in exactly that direction.
If allowed to stand as defined today, these regulations will effectively eliminate a long list of information products currently in use.