|March 30, 2000
Mr. Donald S. Clark, Secretary
Re: Gramm-Leach-Bliley Act Privacy Rule, 16 CFR Part 313 -- Comment
Dear Mr. Clark:
Residential Funding Corporation ("GMAC/RFC") respectfully submits this letter in response to publication of the Federal Trade Commissions Proposed Rule on the Privacy of Consumer Financial Information (65 Fed. Reg. 11174; March 1, 2000).
GMAC/RFC is a wholly-owned subsidiary of one of the worlds largest finance companies, with several of its own subsidiaries. GMAC/RFC made its name in the early 1980s by securitizing jumbo mortgage loans. We continue to do business in that market, and our subsidiaries originate and service mortgage loans, as well as engage in other financial service activities. We are in favor of measures that strike an appropriate balance between consumer privacy concerns and the costs and burdens of compliance with regulatory requirements. We applaud your effort in this endeavor.
We are a member of, and support the comments of, the Consumer Mortgage Coalition ("CMC"). Particularly, we support the explanation and request for clear action concerning the forthcoming regulations as they relate to treatment of investors (and mortgage lenders in a broker context) and requirements to give privacy disclosures. We also believe that it is important that the term "financial" be included in the definition of nonpublic personal information, to be consistent with the definition that appears in the Gramm-Leach-Bliley Act. Finally, we urge all of the agencies to work together to ensure consistency of regulations across types of financial institutions, and an extension of the effective date of the regulations to 12 months past the time they are published.
We appreciate the opportunity to participate in the regulatory process, and we thank you for your consideration of this letter.
Pamela O. Lindula