As long as they work, they should be sufficient. The provisions preceding this sentence already mention sufficient remedies and penalties. General Comments 1. Therefore, we recommend that Commerce make very clear that these principles have been designed solely to meet the European context, and attempts to use them for other purposes would be inappropriate. Additionally, since such statements of purpose may prove ineffective to limit the principles to the European context, it is important that Commerce view these principles with an eye to preserving and accounting for elements of the American context, such as our sectoral approach to regulation and our greater reliance on private enforcement and self-regulation.
Current Regulation is Adequate.
The U.S. banking industry is heavily regulated with significant legal and regulatory controls that adequately protect the privacy of customer information. The European Union needs to understand better how regulation and enforcement works in this country instead of looking for a replication of the bureaucratic form of regulation and enforcement with which Europe is familiar. Federal banking regulators will be quick to require banks to comply with privacy policies based on safety and soundness reasons as well as the requirement not to misrepresent to the public an important bank policy, and even without new laws or regulations such regulators have adequate existing authority to compel compliance. Public Opinion and the Urge to Litigate. Public opinion in the U.S. is a powerful force, and has been roused several times in the last few years over privacy issues, resulting in very prompt suppression of the particular conduct or action that riled the public.