|Sent: Friday, March 31, 2000 3:48 PM
Subject: "Gramm-Leach-Bliley Act Privacy Rule, 16 CFR Part 313 - Comment"
I am writing to express our concerns with the proposed regulations to implement Title V of the GLB Act of 1999.
Sterling Jewelers Inc. operates over 800 retail jewelry stores in the U.S. and is the second largest retail jewelry chain in the United States. As a subsidiary of Signet Group plc (U.K.), we are also part of the largest retail jeweler in the world.
First, we would like you to know that we strongly support the comments filed by the National Retail Federation (NRF) in behalf of the retail industry.
In addition, and like the NRF, we want to emphasize that we have considerable concern about whether retailers can comply within the time frame of the rules, e.g., 11/13/00-12/12/00. This period coincides with the major portion of holiday mailings, during which time we, like most retailers, mail millions of promotional catalogs to our customers. Any additional mailings during this period would constitute a severe burden for us, as well as place a difficult burden on the postal service. Such notices would no doubt confuse consumers who already receive the bulk of their promotional mail during the holiday season. We believe that you should consider extending the period of compliance through the summer months, so that retailers would have through 9/30/01 to comply with notification requirements.
Sterling Jewelers Inc.
William Montalto, Sr.
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