| Sent: Wednesday, March 15, 2000 5:29 PM Secretary RE: Gramm-Leach-Bliley Act Privacy Rule, 16 CFR Part 313 -Comment To Whom It May Concern: We are writing to express our concern with the proposed regulations to implement Title V of the Gramm-Leach-Bliley Act of 1999. The Judicial Judgment Collectors Association represents 350+ Judgment Recovery Specialist, who 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 our 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 institution is defined as "non-public personal information," then what is "public"? Congress seemed to be offering a distinction by describing financial information. We 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." The Judicial Judgment Collectors Association and Judgment Recovery Specialists nationwide 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 to our conduct of business and fulfilling our obligations to consumers. We utilize this information to locate delinquent judgment & child support debtors among other things. Judgment debtors rarely stay in one place for long and the utilization of credit headers and the address and phone information they provide is a vital part of ammunition to locate these debtors and serve justice. If this information is deemed "non-public personal," only the debtors, wrongdoers and criminals will benefit and the law-abiding consumer will be the loser once again. We urge you to define non-public personal information in the manner that Congress intended. I am forwarding you this letter speaking on the behalf of our membership of 350+ members who find this issue of great importance and critical to our business. Should you wish to contact me, please feel free to call me at my office at: Office: 770-997-1688 Email: search49@bellsouth.net Fax: 770-997-7115 Yours truly, Shawn Rolison |