Do you remember pinball?  I am probably dating myself, but I remember standing at the pinball machine, playing well, feeling in complete control, and racking up the points; suddenly the balls gets away.  What to do?  Well, typically the player starts hitting those buttons harder, leaning the hips one way and the body the other, smacking the top, hoping the vibrations will give you an edge.  But if you shake the machine a little to hard al you get is.....TILT  TILT  TILT, flashing in big bright letters across the top of the scoreboard.  The only thing left is moaning, groaning and of course, your friends telling you what you did wrong.  This, I imagine, is how the supervising agencies for financial institutions may be feeling about the proposed rules for Privacy Disclosures.

 

In all of the publications that cater to financial institutions that I have read since March, and that is quite a few, I have yet to see anyone with a kind word about them.  Oh, there are some who like parts of the rules or what they are trying to accomplish, but not so for the model disclosures provided with the proposed rules. 

 

I don't blame them.  They look nice, but why do they have to be three pages or more long.  The same information can be provided in a similar format utilizing a single page printed front and back.  NBP, in fact, offers two versions.  The letter format and the brochure format.  Both contain the same information as shown in the models but without all the unnecessary white space and the font size is readable.  

 

Remember your comments are due on or before the May 29, 2007 deadline. 

 

March 29, 2007

The OCC, Board, FDIC, OTS, NCUA, FTC, CFTC, and SEC (the Agencies) are proposing amendments to their rules that implement the privacy provisions of the Gramm-Leach-Bliley Act (GLB Act), Title V, Subtitle A. These rules  require financial institutions to provide initial and annual privacy notices to their customers. As required under section 728 of the Financial Services Regulatory Relief Act of 2006 (Regulatory Relief Act or Act), the Agencies are proposing a safe harbor model privacy form that financial institutions may use to provide disclosures under the privacy rules.

 

Use the link below to access the full Federal Register document.