CAPITAL CITY BANK

From: Staalenburg, LeAnne
Sent: Monday, August 30, 2004 11:34 AM
To: Comments
Cc: Hutchison, John
Subject: GLBA / EGRPRA Burden Reduction Comment Letter
Importance: High

To Whom It May Concern:

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 (prior to July 1, 2001) served the
purpose of notifying consumer customers of a financial institution's privacy
policy. After that date, a privacy notice is provided to each new deposit,
loan, and other financial services consumer customer at time of account
opening and is posted in each institution's branch offices. The initial
notice is important to consumers because it informs them about the way their institution handles their non-public personal financial information.

Currently, GLBA requires a financial institution to annually provide their
privacy policy notice to consumer customers. At our bank, we have found
clients complaining about getting these notices each year. We send the
majority of these notices as statement stuffers, but there is a segment of
our consumer customer base who do not annually receive a statement. For
those customers, we must do a direct mail to get them the privacy notice.
The annual notice requirement is an especially costly (in printing, postage
and man hours) and non-productive exercise that adds to the institution's
regulatory burden and provides the customer with no new information.

After an institution has provided an initial privacy policy notice, unless
the policy changes, it seems impracticable to provide that same policy
annually. The GLBA notice requirements would be much more meaningful to the customer and efficient and cost effective to the financial institution if
the notices are sent only if the institution's privacy policy changed. If
notices are mailed annually (even with no policy change), consumer customers will be less likely to read and notice when the policy has been revised. If a customer gets a privacy notice each year, he/she might not notice if their institution (who initially was not subject to the opt-out provision) changed their policy where opt-out would apply.

Thank you for allowing me the opportunity to comment.

LeAnne Bailey Staalenburg, CRCM
Assistant Vice President
Compliance Privacy & Training
Capital City Bank
P O Box 900
Tallahassee, FL 32302