ReceiVed CFTC 

May 29,2007 COMMENT i 

Eileen Donovan ~ 

Acting Secretary of the Commission · · 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 2181 Street, NW 

Washington, DC 20581 

Jennifer J. Johnson, Secretary 

Board of Governors 

of the Federal Reserve System 

201h Street & Constitution Avenue, NW 

Washington, DC 20551 

Attention: Docket No. R-1280 

Mary Rupp, Secretary of the Board 

National Credit Union Administration 

1775 Duke Street 

Alexandra, VA 22314-3428 

Regulation Comments 

Chief Counsel's Office 

Office ofThrift Supervision 

1700 G Street, NW 

Washington, DC 20552 

Attention: OTS-2007-0005 

JAMES P. GHIGLJERI. JR. 

Chairma11 

CYNTHIA BLANKE:-ISHIP 

Chainnan-Et.,·r 

R . .-.ucHAEL MEN"LIES 

KEN F. PARSONS, SR. 

'Tt'-'il.(Ufl'l" 

WJLUAM C. ROSACKER Stfr,•tary 

TERRY J. JORDE 

lm.lne.•diute PQlt O~r~irnrmr 

CAMDEN R. FINE 

Prcsidc:nt .1nd CEO 

Robert E. Feldman, Executive Secretary 

Attention: Comments 

Federal Deposit Insurance Corporation 

550 1 ih Street, NW 

Washington, DC 20429 

Federal Trade Commission 

Office of the Secretary 

Room 135 (Annex C) 

600 Pennsylvania A venue, NW 

Washington, DC 20580 

Attention: Model Privacy Form 

FTC File No. P034815 

Office of the Comptroller of the Currency 

250 E Street, SW 

Mail Stop 1-5 

Washington, DC 

Attention: Docket Number OCC-2007-0003 

Nancy M. Morris, Secretary 

Securities and Exchange Commission 

100 F Street, NE 

Washington, DC 20549-1090 

Attention: File Number S7-09-07 

Model Privacy Form 

Interagency Proposal for Model Privacy Form Under the Gramm-Leach-Bliley Act 

Dear Sir or Madam: 

The Independent Community Bankers of America (ICBA) 1 appreciates the 

opportunity to comment on the proposed interagency model privacy form designed to be 

1 The Independent Community Bankers of America represents the largest constituency of community 

banks of all sizes and charter types in the nation, and is dedicated exclusively to representing the 

IN DEPENDENT COMMUNITY BANKERS of AM E R I CAThe Nation '.~ Voice for Community Banks 

1615 L Street Nl1~ Suite 900, Waslzingtoll, DC 20036 • (800)422·8439 • FAX.: (202)659·3604 • Email: info@icba.or_q • www.icba.arg 
used by financial institutions to disclose their information sharing practices with 

consumers. ICBA applauds the agencies for working to simplify the disclosure forms to 

provide more meaningful information for consumers and especially for working with 

consumers to develop the proposed revisions. 

Background 

The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to provide 

initial and annual notices to customers about the information they collect and share. 

When the GLBA requirement was originally implemented, the banking agencies 

provided sample clauses for banks to use. The privacy rule does not prescribe any 

specific format or standardized wording for these notices but banks that use the sample 

clauses are considered in compliance. However, many banks find the sample clauses 

unduly complex and ignored by consumers. 

Based on consumer research and required by the ICBA-supported Financial 

Services Regulatory Relief Act of2006, the four federal banking agencies, the NCUA, 

the Federal Trade Commission, the Securities and Exchange Commission and the 

Commodity Futures Trading Commission have proposed new model forms banks may 

use- at their option- to disclose information sharing practices. ICBA strongly supports 

pending legislation that would eliminate the annual notice requirement for banks that do 

not change their privacy policies and only share information permitted by one of the 

statutory exceptions that do not require an opt-out, but even when such legislation passes 

bankers will need to provide an initial notice. The new model forms would provide an 

alternative mechanism for banks to notify customers about their privacy policies and 

procedures. 

Summary of ICBA Comments 

2 

ICBA believes that the proposed revisions are a step in the right direction. While 

we continue to urge Congress to provide an exemption from the annual notice 

requirements in appropriate circumstances, simplified disclosures - especially those 

based on consumer testing- will help provide consumers with information they want and 

need. 

While the proposed forms are an improvement over the existing sample clauses, 

additional flexibility is needed to make them truly useful and useable. Restricting the 

format of the form, especially requiring single-sided 8 Yz by 11 sheets ofpaper, will 

unnecessarily increase costs for printing and mailing without a clearly demonstrated 

interests of the community banking industry. ICBA aggregates the power of its members to provide a 

voice for community banking interests in Washington, resources to enhance community bank education 

and marketability, and profitability options to help community banks compete in an ever-changing 

marketplace. 

With nearly 5,000 members, representing more than 18,000 locations nationwide and employing over 

268,000 Americans, ICBA members hold more than $908 billion in assets, $726 billion in deposits, and 

more than $619 billion in loans to consumers, small businesses and the agricultural community. For 

more information, visit ICBA's website at www.icba.org. 

IN DEPENDENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Community Banks 

1615 l. Street NW. Suite 900. WtTShington. DC 20036 • (800)422·8439• FAX: (202)659·3604 • Emnil: inj'o@icba.org • www.icbn.org 
benefit to balance the increased costs. ICBA strongly recommends that the final rules 

provide guidance and parameters for companies to follow without being so prescriptive. 

A one-size-fits-all approach often leads to unnecessary and unintended consequences .. 

ICBA also believes that there are redundancies in the proposed models that the agencies 

should seek to eliminate during the next phase of consumer testing. 

Because many banks have developed disclosures relying on the sample clauses 

created by the regulators, ICBA believes the sample clauses should continue to be 

available. Because many currently used disclosures were developed in reliance on 

regulatory models, we recommend that the agencies allow at least two years before 

eliminating the safe harbor for the current sample clauses. We urge the agencies to post 

the new models on their websites to allow community banks to easily download and 

customize the forms for distribution. And finally, we agree that development of 

guidelines for Internet disclosures would be useful. 

The Proposal 

3 

The proposed models are based on extensive research with small groups of 

consumers2 and a separate requirement in last year's regulatory relief bill that model 

forms be comprehensible, clear and conspicuous and allow consumers to easily compare 

practices at different financial institutions. ICBA has long advocated consumer testing to 

develop meaningful disclosures. While the models were developed through consumer 

testing with small groups, the agencies anticipate completing the second phase of testing 

of the models with a broad, statistically significant cross-section of consumers before the 

rules are finalized. 

Using the new forms is optional, but banks that use the model will have a "safe 

harbor" and be considered in compliance with the disclosure requirements. As an 

incentive to use the new models, though, the agencies propose to eliminate the safe 

harbor for the current sample clauses. 

Using the Proposed Models 

An informal survey of ICBA member banks found that many are likely to use the 

model forms to ensure compliance with the rule's requirements. Most found the new 

forms more consumer-friendly than the existing sample clauses. The proposed revisions 

are likely to benefit community banks since comparison between different institutions 

will be easier, making it more readily apparent that community banks are less likely to 

share information other than as permitted by existing statutory exceptions. 

However, while ICBA finds certain advantages in the proposed models, there are 

a number of concerns about the format that need to be addressed - primarily the physical 

bulk of the form and the costs for printing and postage to distribute an 8 1i x 11 singleside form. A one-page form that provides the information would likely be simpler and 

more likely read by consumers. The longer the. form, the more likely it will still be 

2 As noted in the interagency report on model privacy notices issued in early 2006, a second 

phase of testing with greater numbers of consumers designed to produce statistically significant 

information has not been finalized but is expected to be conducted in the near future. Evolution 

of a Prototype Privacy Notice, February 28, 2006. 

INDEPENDENT COMMUNITY BANKERS of AMERICA The NCltion's Voice for Community Banks 

161'5 L Street N\1~ Suite 900, Wasllinyton, DC 20036 • (800)422·8439• FAX: (202)659·3604 • Email: in[o@icba.Or!J • www.icba.org 
ignored by most consumers and therefore the less likely the revisions will achieve their 

goal. Given the limited consumer testing used to develop the models, the agencies must 

ensure that consumers will actually read the models during the next consumer testing 

phase. 

Overall, though, ICBA believes that the proposed models will allow community 

banks to accurately disclose their information sharing practices since most community 

banks limit their information sharing to that permitted by existing statutory exceptions. 3 

4 

Since many community banks do not share information in ways that permit a 

consumer to opt out, a brief statement needs to be added to the models explaining that not 

all financial institutions will offer customers an opt-out. The existing sample clauses 

often confuse community bank customers, in part due to statements on opting out by 

consumer activists and consumer reporters who fail to explain that not all banks must 

offer an opt-out because they already limit information sharing. To alleviate this 

confusion, ICBA recommends a brief sentence to explain that opting out is not always 

available. 4 

ICBA also believes that as long as community banks and other small companies 

are compelled to provide an annual privacy notice, the agencies should develop a 

simplified alternative for those companies that only share information under the existing 

exceptions. While the models are very useful, since so many community banks will 

likely place a "no" or "not applicable" in many boxes, a very streamlined form for those 

institutions would be both useful arid economical. 

Format of the Model 

The regulatory relief act requires that model forms be comprehensible, clear and 

conspicuous and allow consumers to easily compare privacy practices of different 

companies. The proposed models are two or three 8 Yz x 11 pages printed on one side. 

Banks would be limited in the amount of additional information they could include but 

could insert the bank's name and logo, contact information and information about 

affiliates, non-affiliates and joint marketing partners. The statute also requires the model 

form to use an easily readable type font; the agencies propose 1 0-point font for the 

minimum type size as well as providing specific requirements for the spacing between 

lines depending on the type of font. And, while many fonts could be used, the proposal 

cautions that banks using highly stylized type will not meet the model form's standard. 5 

3 Companies that share information with affiliates and other companies are likely to find the 

models difficult- if not impossible - to use because the proposal greatly restricts flexibility for 

disclosures. 

4 As drafted, the model forms do not explicitly provide such a statement. A logical point to insert 

such a statement would be on the second page of the model on the last line of sharing practices 

after the sentence beginning "state laws and individual companies .. . " The proposed addition · 

could read, "Some companies limit how they share information about you and so are not required 

to give you the option to opt out." 

5 Three years ago, when the Federal Reserve proposed similar specific requirements, ICBA raised 

concerns about the lack of flexibility and the potential regulatory burden inherent in such highly 

proscriptive rules. 

IN DE PEN DENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Communiiy Banks 

1615 L Street NW, Suite 900, Washin!]Wn, DC 20036 • (800)422·8439• FAX: (202)659·3604 • Email: info@icba.org • w.vw.icba.org 
5 

ICBA recommends the final rule be sufficiently flexible to allow individual 

companies to present the information in ways that are most meaningful for their own 

customers. There are many ways to style disclosures to be easily read. Underlining, use 

of all capital letters, different font styles, holding and so forth can all be used effectively 

to provide clear disclosures. Homogenization through regulation creates an inflexibility 

that will make the disclosures less effective since all disclosures will look alike and 

therefore will be less likely to be read by consumers. Regulatory restrictions also prevent 

banks from experimenting to develop more effective disclosures that are appealing and 

welcome .to consumers. A brightly colored folder would get more attention than a bland 

8 Yz x 11 sheet on buff paper. If the forms are so bland that consumers ignore them, the 

potential impact is less meaningful disclosure. And, the more the disclosures look alike, 

the more difficult it will be for consumers to distinguish individual companies. 

ICBA does agree that some guidelines are helpful and also prevents creative 

presentation that obscures important information. However, the final rule should not be 

so restrictive as to eliminate all flexibility and originality. 

Single Sided Format. The proposal would require information be printed only on 

one size of a page. According to the agencies, this requirement would let consumers 

view each page of the form simultaneously. ICBA does not agree that a single sided 

format is necessary and would unnecessarily increase costs without significantly 

providing benefits for consumers. And, the more pages to the disclosure, the less likely 

consumers will read the entire form - making the changes counterproductive. It is also 

troublesome that the proposal is recommending a change that would increase postage 

costs when the U. S. Postal Service recently increased the costs for mailing. 6 

At a minimum, requiring the forms to be printed on one side will substantially 

increase costs for printing and postage- and these costs will be passed along to 

consumers. While preliminary research with a limited number of consumers showed a 

preference for single-side printing to allow comparison of information, nothing indicates 

whether consumers were asked or would be willing to pay extra for this benefit. A 

simple statement printed on the bottom of the front that states, "see reverse side for 

sharing practices and definitions," possibly printed in all capital letters, should be 

sufficient for most consumers. 

ICBA also disagrees with the requirement that the forms be restricted to 8 Yz x 11 

sheets of paper. This inflexibility and one-size-fits-all mandate is the very type of 

regulation that increases regulatory burden and costs. Absent some clear demonstration 

that 8 Yz x 11 paper produces a benefit that outweighs the costs- which is not presentICBA urges the agencies not to include such inflexibility in the final rule. As long as the 

information is presented clearly and can easily be read by consumers, the size of the 

paper should be irrelevant. 7 

6 Requiring multiple page~ and single-sided printing is also decidedly unsound from an 

environmental perspective. 7 Dictating the specific printing formula in the rule is similar to a mandate the National Credit 

Union Administration required for disclosures for conversion of a credit union to a mutual 

IN DE PEN DENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Community Banks 

1615 L Street Nl¥. Suite 900, Wmhington. DC 20036 • (800)422·8439 • PAX: (202)659·3604 • Email: in[o@icba.org • www.icba.org 
6 

ICBA strongly recommends that the final rule allow individual banks to 

determine the best format to use to present information and that the rule not restrict banks 

to a specific size of paper or single-sided printing. The final rule should be flexible 

enough to allow banks to determine the size of the paper and whether to produce it in a 

brochure or other format. 

Using a Table Format. ICBA believes that presenting the information in a table 

format make the disclosures easier to read and understand. 8 It presents the information in 

a more concise and logical order and is clearer than most privacy notices used today. It 

also clearly presents information about what is shared and what the consumer can control. 

However, ICBA also finds that some of the information is unnecessarily repeatedperhaps leading to the need for three pages. Elimination of repetitive information would 

help streamline and shorten the model. This is something that ICBA recommends the 

agencies further explore during the next phase of consumer testing. 

Use of Colors. To ensure the disclosures are "clear and conspicuous," the 

proposal specifies that banks must use either white or a light color paper, such as cream, 

with black or suitable contrasting ink to make the form easy to read. Other colors, such 

as colors for the bank's logo, could be used as long as they do not detract from the basic 

information in the model. 

ICBA believes it is important to allow individual banks to customize the notices 

in ways that allow individual banks to differentiate themselves from their competitors. 

Allowing banks to vary color schemes or add the logos is therefore very important. One 

of the goals of the revisions is to allow consumers to easily compare the information 

sharing practices of different banks. If all forms are identical in form, color and format, it 

will defeat that goal because all the forms will look alike and it will make it difficult to 

easily identify individual institutions. Consumers should be able to easily identify and 

distinguish which disclosure is issued by which bank. Each bank should be given enough 

flexibility to determine how it will customize its disclosure since the bank is in the best 

position to determine how to most appropriately communicate with its own customers 

and its own market. 

The Information Presented 

Page One. The first page provides background information and a table that 

describes the types of information sharing allowed by federal law, which types of sharing 

the bank does, whether the consumer can opt out from information sharing, and the 

bank's contact information. The top half of the page is basic generic information while 

the bottom half is bank-specific presented in a table format similar to the Schumer Box 

used for Truth-in-Lending Act disclosures. The table provides information about the 

savings association in Texas; pundits referred to that as the "origami requirement" and the agency 

was roundly criticized by the magistrate in that case. Community Credit Union v. NCUA, E. D. 

Tex., August 2005. 

8 The Federal Reserve is currently working to revise infonnation in credit card disclosures. 

Consumer testing by the Federal Reserve found that tabular disclosures are very useful and 

infonnative. 

INDEPENDENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Community Baoks 

16/5 L Street NW, Suite 900, W,1shingto11, DC 20036 • (800)422·84 39 • FAX: (202)659·.3604 • Em nil: in[o@icba.org • www.icba.or_q 
bank's specific information sharing policies and provides important context about what 

information sharing a bank actually does relative to what it could do. According to the 

agencies, this is the "heart" of the model notice. 

On the bottom half of the model, it states that the bank may share information 

with affiliates for everyday business purposes. It states the bank will share "information 

about your transactions and experiences." Since the statement "transactions and 

experiences" may not be clear for the average consumer, including examples to clarify 

what transactions and experiences are would help. Again, this is an element that the 

agencies may want to further explore during the next phase of testing. 

7 

Pages Two and Three. The second page provides additional explanatory 

information that, when combined with the disclosures on the first page, ensures the model 

provides all the elements required by the GLBA. Some of the definitions, such as 

information about a bank's affiliates, are bank-specific. If a bank does not have affiliates, 

it would explain on this page that "[Bank] has no affiliates." 

The third page is the opt-out form for use by banks that share information in a 

way that gives consumers this right. If a bank is not required to offer an opt-out, this 

page is not required. The page lists three common ways customers can opt out: 

telephone, Internet, or mail (a bank would only list the method or methods for opting out 

that it offers). The model also provides flexibility for banks that offer additional opt-out 

choices beyond those required by the existing privacy rules, such as the ability to opt out 

of joint marketing. 

ICBA does not currently have any comments on page two of the disclosure or the 

opt-out form. 

Elimination of the Existing Safe Harbor 

The proposed models are intended to replace the existing sample clauses provided 

by the regulatory agencies that banks currently use. Because research and commentators 

have found the existing language confusing- what some have called "landfill fodder'' 

since many consumers ignore the notices - the agencies propose to eliminate the existing 

sample clauses and the safe harbor for using them from the privacy rule once the new 

model forms are finalized. However, because most banks use some variation of the 

sample clauses in their existing privacy notices, the proposal would allow a one-year 

transition period once the model forms become final. After that one year period, a bank 

using the existing language would no longer be automatically in compliance with the 

disclosure requirements. 

ICBA is concerned about eliminating the safe harbor for the existing sample 

clauses in only one year. Many community banks developed privacy notices in reliance 

on the sample clauses crafted by the federal regulators. While it is true the sample 

clauses have been criticized for the legalese used to explain a consumer's rights, for over 

six years banks have relied on the approval by the federal regulators in using the clauses. 

If the models are as effective as the agencies believe, that will serve as added incentive 

for banks to begin using the new models as soon as possible. 

INDEPENDENT COMMUNITY BANKERS o( AMERICA The Nation's Voice for Community Banks 

I 615 L Street Nl¥. Suite 900, Washinf}lon. DC 20036 • (800)422·8439 • FAX: (202)659·3604 • Email: irzjo@icba.org • www.icbn.org 
8 

To let banks transition from the existing regulatory regime to the new model 

notices, ICBA agrees that a transition period is appropriate. However, we recommend 

that since the existing safe harbor for use of the sample clauses is based on models 

designed by the federal regulatory agencies that a longer transition period be allowed. 

ICBA believes that two years instead of the one year proposed would be less burdensome 

transition. A two-year transition will allow banks to adjust policies and procedures much 

better within the constraints of the annual notice requirement. For example, some banks 

also distribute the disclosures in other languages such as Spanish, and two years will 

allow better time to develop appropriate translations since they are not provided by the 

regulators. In addition, since banks furnish the annual notice at different times during the 

year, a one year transition may be awkward for banks depending on when they mail their 

annual notices. For example, if the final rule becomes effective in October and the bank 

normally distributes its privacy notices in December, the proposal would actually only 

allow two months for the bank to change procedures to comply with the new 

requirements. A two-year transition would help ease this burden. 

After two years, eliminating the safe harbor for the existing clauses will 

encourage all banks to use the new models and will help move towards more 

standardized disclosures. 

Model Internet Disclosures 

The agencies have asked whether a special disclosure form should be designed for 

the Internet. Since Internet and online banking are steadily increasing, ICBA believes it 

would be useful for the agencies to issue specific guidelines for Internet disclosures. This 

is especially important if the final rule outlines specific parameters for fonts, other print 

styles and general overall format for the printed disclosures. However, any guidelines for 

the Internet - as with the final guidelines for the printed disclosures - should allow 

enough flexibility for individual banks to tailor the disclosures to their own market and 

audience. For example, banks are starting to explore technologies that allow on-line 

banking using mobile phones, and any disclosures must be able to be presented using the 

new technology. In addition, technology is constantly changing, and any guidelines must 

be flexible enough to allow for new technologies not currently in use. It would also be 

helpful for the agencies to provide templates in electronic format that can be easily 

adapted by banks to their own online banking systems. 

Easy Access to Model Forms 

ICBA believes it would be helpful for the agencies to post the model forms on the 

agencies' websites. Posting the models will make them readily available for banks to 

download and customize for printing. By providing a downloadable template, the 

agencies also will alleviate some of the burdens faced by community banks transitioning 

to the new models, a step especially helpful for community banks since they have limited 

resources. This will help with the transition and will also encourage banks to adopt the 

model disclosures. Therefore, this is a step ICBA fully supports. 

IN DE PEN DENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Community Banks 

J 6 J 5 L Street NW Suite 900. WashintJfOII. DC 20036 • (800)422·8439 • PAX: (202)659·3604 • Email: info® icba.or.q • www.icba.org 
Special Privacy Notices 

One question that has been raised is whether a bank should be required to send a 

special notice or take other steps when it changes its privacy practices. The purpose 

behind the special notifice would be to draw attention to the change. ICBA believes this 

would be appropriate -but only if the annual notice requirement is eliminated. If a bank 

changes policies and procedures that affect a customer, the customer should be notified 

and given an opportunity to take any appropriate steps. This is especially true if the 

change allows information to be shared that was not previously shared. 

Under existing law, the annual privacy notice does little to inform consumers. 

9 

However, if the annual notice is eliminated and a bank must notify a customer about 

changes to information sharing policies and procedures- similar to notices about changes 

in interest rate or other terms for credit cards- it is more likely the customer will pay 

attention to the notice. This one step will help make the disclosures more meaningful. 

Social Security Numbers for Opt-Out 

Recently, a great deal of attention has been paid to the overuse of Social Security 

Numbers and the commensurate increase in identity theft. Currently some banks request 

customers to provide their Social Security Number as a means to opt out. Depending on 

how the bank's software programs are configured, a Social Security Number may be the 

easiest mechanism to accurately identify the customer. While some banks report having 

a Social Security Number is not needed to allow a customer to opt out, and that it can be 

accomplished using a name and address or account number, ICBA believes that banks 

should still be permitted to request the Social Security Number. 

It is important to recognize that banks are required to maintain Social Security 

Numbers on their customers for a variety of reasons, such as compliance with federal 

law9 

or to report income on interest-earning accounts to the Internal Revenue Service. 

Therefore, ICBA opposes banning use of Social Security Numbers for opting out, but 

recommends that the agencies consider issuing an advisory to encourage banks to 

consider alternatives when and where possible. Before going beyond an informal 

advisory, though, ICBA recommends that the agencies thoroughly explore the issue, 

especially in light of pending legislation in Congress that would impact the use of Social 

Security Numbers in many contexts. 

Conclusion 

ICBA commends the agencies for working with consumers to develop these 

model privacy disclosure forms. The models are an improvement over the existing 

sample clauses. While it is appropriate to encourage companies to use the new models in 

place of the existing sample forms, ICBA recommends a longer period - at least two 

years - to allow companies to transition from existing disclosures to the new models, 

especially since many community banks currently use the sample clauses that were 

developed by the regulatory agencies. 

9 All banks are required under the Customer Identification Program rules issued under the USA 

PATRIOT Act to obtain a Social Security Number. 31 CFR 103.121. 

INDEPENDENT COMMUNITY BANKERS of AMERICA The Nation's Voice tor Communi(}' Banks 

1615 L Street NW. Suite 900, Washington, DC 20036 • (800)422·8439 • FAX: (202)659•3604 • Email: in[o®icba.01;q • www.icb<1.org 
10 

While the new models are an improvement, elements of the proposal are too 

prescriptive. Additional flexibility is needed before the rules are finalized. For example, 

requiring the forms be printed on 8 Y2 by 11 sheets and only on one side will be 

unnecessarily expensive to print and mail. In addition, ICBA urges the agencies to 

develop an additional streamlined form that can be used by the many community banks 

that do not offer an opt-out and that only share information under one of the existing 

statutory exceptions. 

Thank you for the opportunity to comment. ICBA looks forward to continuing to 

work with the agencies to develop streamlined privacy disclosure forms that provide 

consumers with meaningful and useful information about the information sharing 

practices of community banks. If you have any questions or need additional information, 

please contact the undersigned by telephone at 202-659-8111 or by e-mail at 

robert.rowe@icba.org. 

Sincerely, 

7~1?~=--- Robert G. Rowe, III 

Regulatory Counsel 

----------------

IN DE PEN DENT COMMUNITY BANKERS of AMERICA The Nation's Voice for Community Banks 

1615 L Street NW. Suite 900, Washington. DC 20036 • (800)422·8439 • FA X: (202)659·3604 • Email: in[o@icba.org • www.icbn.org