| Sent: Friday, March 31, 2000 5:47 PM Subject: Proposed Financial Privacy Rule Attached are the comments of the American Financial Services Association, which are strongly endorsed by American General Finance. (See attached file: Privacy Comment Letter_Final FTCa.DOC) Particularly, we believe a simplified model disclosure, such as the following, should be allowed if the consumer will receive notice of the right to get a full disclosure on each billing statement. ------------------------------------------------------------------------------
------------------------------------------------------------------------------ Also, in lieu of the annual notice, it should be permissible to give notice of the right to receive a full privacy disclosure on each billing statement and provide one free copy of the full notice every 12 months. This would avoid the cost and difficulty of providing separate notices to all consumers. The final rule should take all reasonable steps to minimize the amount of additional paper disclosures that consumers receive. We believe that customers should receive clear notice of their right to opt out of sharing of their financial information. But we do not believe consumers need to receive detailed statements of a creditor's policies unless requested. We also believe that the Rule must clearly address the various delivery methods used for consumer credit. Separate sections of the rule are needed for the four, basic types of consumer credit transactions: (a) direct credit (loans, credit cards), (b) direct credit with a co-branded partner or other service provider, (c) indirect lending (mortgage brokers or joint applications to multiple lenders), and (d) indirect sales credit (the purchase of closed-end and revolving credit sales by assignees). Thank you for your efforts to make this Rule as workable and understandable as possible. Please contact me if you have questions regarding the above. Christian T. Jones |