APRIL 2, 2004
In a comment letter to federal regulators, the ICBA expressed support for development of an optional short-form privacy notice. Eight federal agencies are currently reviewing the Gramm-Leach-Bliley Act privacy requirements to assess whether to develop short-form privacy notices that would address criticisms that existing notices are overly complex and legalistic.
While expressing support for a more streamlined form, the ICBA strongly recommended that the form be optional, since any short-form notice would require the redesign of forms, retraining of staff and, possibly, reprogramming of software. The ICBA stressed that making any alternative forms optional is especially important for community banks that already use a "long" form that is actually relatively short because they do not share information outside one of the permitted exceptions and are not required to offer an opt-out. ICBA's letter also noted that any optional short form notice should contain all required elements so it can be used instead of the existing long form, since having both a long form privacy notice and a short form could be burdensome for banks and confusing to customers. The ICBA strongly encouraged the agencies to work to eliminate the annual notice requirement, especially for banks not required to offer an opt-out.
For the full text of ICBA's letter, see www.icba.org.