Received CFTC 

RecOrds Section 

5/~1/o1 

STATE SlREEf. .. ... 

Stefan M. Gavell 

Executive Vice President and Head of 

Regulatory and Industry Affairs 

State Street Corporation 

1 lincoln Street 

P.O. Box 5225 

COMMENT Boston, MA 02206-5225 

Telephone: 617-664-8673 

Facsimile: 617-664-4270 

smgavell@statestreet.com 

Office of the Comptroller of the Currency 

250 E Street, S.W. 

Mail Stop 1-5 

Washington, DC 20219 

Via: www.regulations.gov 

Re: Docket ID OCC-2007-0003 

Mr. Robert E. Feldman 

Executive Secretary 

Attention: Comments 

Federal Deposit Insurance Corporation 

550 17th Street, N.W. 

Washington, DC 20429 

Via: Comments@FDIC.gov 

Re: RIN 3064-AD16 

Ms. Mary Rupp 

Secretary of the Board 

National Credit Union Administration 

1775 Duke Street 

Alexandria, Virginia 22314-3428 

Via: regcomments@ncua.gov 

Re: RIN 3133-AC84 

.. Ms. Nancy M. Morris, Secretary 

Securities and Exchange Commission 

100 F Street, N.E. 

Washington, DC 20549-1090 

Via: comments@sec.gov 

Re: File Number S?-09-07, Model Privacy 

Form 

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Ms. Jennifer Johnson, Secretary 0 § 

Board of Governors of the Federal ReMrve :::-

System ~ :::< 

20th Street and Constitution Avenue, rit:W. r" 

Washington, DC 20551 ~ V"l 

Cl :g :;o ~ .. 

Via: regs.comments@federalreserve.gij$' \.t-1 

Re: Docket No. R-1280 ~ 

Regulation Comments 

Chief Counsel's Office 

Office of Thrift Supervision 

1700 G Street, N.W. 

Washington, DC 20552 

Attention: OTS-2007-005 

Via: www.regulations.gov 

Re: Docket ID OTS-2007 -0005 

Federal Trade Commission 

Office of the Secretary 

Room 135 (Annex C) 

600 Pennsylvania Avenue, N.W. 

Washington, DC 20585 

Via: www.regulations.gov 

:J::> ·~ 

Re: Model Privacy Form. FTC File No. 

P034815 

Ms. Eileen Donovan 

Acting Secretary of the Commission 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, DC 20581 

Via: secretary@cftc.gov 

Re: RIN 3038-AC04 
Interagency Proposal for Model Privacy Form Under the Gramm-Leach-Biiley Act 

Dear Sir or Madam: 

State Street Corporation ("State Street") appreciates the opportunity to comment on the 

"Interagency Proposal for Model Privacy Form under the Gramm-Leach- Bliley Act" ("the 

proposed rule") issued on March 29th. 2007. State Street, a state chartered Federal Reserve 

member bank headquartered in Boston, Massachusetts, specializes in providing institutional 

investors with investment servicing, investment management and investment research and 

trading. With $12.3 trillion in assets under custody and $1.8 trillion in assets under management 

as of March 315

\ 2007, State Street operates in 26 countries and more than 100 markets 

worldwide. 

State Street's existing privacy notices are based upon sample clauses contained in Appendix A 

of final Gramm-Leach-Biiley Act ("GLBA") consumer privacy rules issued on June 1st, 2000 

("the Sample Clauses"). Our privacy notices have been carefully crafted to provide customers 

with pertinent information in as clear and as concise of a format as possible. Under State 

Street's business model, where the sharing of non-public personal information is extremely 

limited, the Sample Clauses have provided a suitable basis for the very simple privacy notices 

which we provide our customers. 

Once a final rule is issued, State Street will carefully evaluate the potential benefits of the new 

model privacy form. As noted however, we believe that our current privacy notices, based upon 

the Sample Clauses, have been effective. It is therefore unclear if adopting a new privacy form 

will be beneficial to the customers receiving these notices. In addition, we are also concerned 

that the proposed model format, involving the use of two full-sized sheets of paper (8.5 X 11 

inches) and a specified font, may prove costly to implement. 

Therefore, State Street strongly recommends that any model privacy form adopted as part of a 

final rule be offered as an alternative, rather than as a substitute, for existing Sample Clauses. 

Financial institutions should be provided with a safe harbor under either alternative. We note 

that this approach is consistent with Congressional intent under the Financial Services 

Regulatory Relief Act of 2006, which specifies the joint development of a "model form which 

may be used at the option" of a financial institution but does not preclude reliance on the 

existing Sample Clauses. 

Thank you once again for the opportunity to comment on the proposed model privacy form. We 

urge the Agencies to ensure that any new model privacy form is adopted as an alternative, 

rather than as a substitute, for the Sample Clauses contained within existing GLBA rules. 

Sincerely, 

Stefan M. Gavel! 

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