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Re: Grarnrn-Leach-Biley Act Privacy Rule 16 C.F.R. Part 3 13 - Comment

By Zalenski, Walter E.

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Book Id: WPLBN0000149729
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Title: Re: Grarnrn-Leach-Biley Act Privacy Rule 16 C.F.R. Part 3 13 - Comment  
Author: Zalenski, Walter E.
Volume:
Language: English
Subject: Trade, Import and export controls, Federal Trade Commission (U.S.)
Collections: Economics Publications Collection, Federal Trade Commission
Historic
Publication Date:
Publisher: Government Printing Office

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Zalenski, W. E. (n.d.). Re: Grarnrn-Leach-Biley Act Privacy Rule 16 C.F.R. Part 3 13 - Comment. Retrieved from http://www.worldebooklibrary.com/


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Government Reference Publication

Excerpt
Dear Sir: We are pleased to have this opportunity to respond to the Federal Trade Commission's (Commission) request for comments on its proposed regulations implementing Title V of Grarnm-Leach-Bliley Act (G-L-B Act), P.L. 106-102. Our comments are limited solely to the impact of the proposal on debt buyers. The debt buying industry, as discussed herein, is principally engaged in purchasing consumer receivables in default. Debt buyers generally attempt to collect such obligations after they are acquired. We will assume for purposes of this letter that debt buyers are debt collectors, as defined by the Fair Debt Collection Practices Act (FDCPA), and financial institutions, as defined by the G-L-B Act. The purpose of this comment is to explain that debt buyers do not have a customer relationship with consumer debtors whose obligations are purchased. The Commission's proposal provides that a customer relationship is characterized by a continuing relationship between a consumer and a financial institution. Proposed fj 3 13.3(i); 65 Fed. Reg. at 1 1,189 (emphasis supplied). Any financial institution with a customer relationship must provide to each customer a detailed written disclosure of its privacy policy at the inception of the relationship and at least annually thereafter. Proposed 5 3 13.4 and tj 3 13.5. This is true even when the institution does not disclose nonpublic personal information about the customer to any nonaffiliated third party.

 

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