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Premier
Bank
From: Matt Brown
Sent: Monday, August 23, 2004 1:05 PM
To: Comments
Subject: EGRPRA
The Gramm-Leach-Bliley
Act of 1999 established requirements to provide privacy notices at
the time of account opening and on an annual basis. The initial mailing
of privacy notices served the purpose of notifying customers of a
financial institution’s privacy policy. A privacy notice is
provided to each new deposit, loan, and other financial services
customer at time of account opening and is posted in each institution’s
branch offices. After an institution has provided an initial privacy
policy notice, unless the policy changes, it seems impracticable
to provide that same policy annually. The rule could be more meaningful
and efficient if the notices are send only if the policy changed.
For small institutions, under $1 billion in assets, that do not share
customer information, this is an especially costly and non-productive
exercise that adds to the institution’s regulatory burden and
paper work.
Matt Brown
President & CEO
Premier Bank
P.O. Box 3606
Tallahassee, Fl 32315
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