Financial Literacy and Education Campaign Strategies


Financial literacy should start early. Fundamental concepts such as the need for savings should be started in elementary school and be carried through the educational process.

Unfortunately, dysfunctional concepts such as “easy credit” are often instilled as college-age students are lured with multiple credit card offers and as television advertisements portray “the good life” as being fueled with credit card accounts. With the average household credit card indebtedness estimated at $9,000, these messages need to be countered early on with education about the responsible uses of credit.

Comments on FACTA Disposal Rule, RIN 3064-AC77: Fair and Accurate Credit Transaction Act Disposal of Consumer Report Information and Records


Irresponsible handling of sensitive consumer data has long been cited as a contributing factor to identity theft. A practice known as "dumpster diving" is often claimed by thieves themselves as the source of the data that allowed them to commit the crime. Sensitive data discarded by a financial institution provides a prime opportunity for a crook to access another's personal data.

By enacting §216 requiring proper disposal of consumer information, Congress has given the public one of the strongest tools yet in combating the growing crime of identity theft. It is now up to the financial regulators and the FTC to carry out Congress' intent by adopting strong regulations to ensure identity theft is no longer fed by careless and irresponsible disposal of confidential consumer data.

Comments on FACTA Disposal Rule: Disposal of Consumer Report Information and Records


The Disposal Rule, as proposed, covers a wide array of entities that compile and use consumer data. Once finalized, the Rule will impose records disposal requirements on entities that before had no reason to consider the consequences of irresponsible information handling practices.

Comments Regarding the Use of Personal Medical Data by Financial Institutions


The proposed rule generally prohibits a creditor from obtaining and using medical information for making decisions about a consumer's credit eligibility. The rule then makes an exception that allows creditors to obtain and use financial information that happens to be related to medical debts, expenses and income.

Federal Agencies' Joint Request for Comment: Alternative Forms of Privacy Notices


The Gramm-Leach-Bliley Act (GLB) requires financial institutions to give customers annual notice of how personal information is collected and disclosed, and, under limited circumstances, a means for customers to control information flow. The notices delivered to consumers, beginning with the effective date of July 1, 2001, until now have generated substantial criticism from all interested parties. As the ANPR notes, there have been broad-based concerns expressed by representatives of financial institutions, consumers, privacy advocates, and Members of Congress.

In response to numerous concerns expressed by all stakeholders about privacy notices, the FTC convened a workshop in December 2001, just five months after financial institutions were required to send the initial privacy notice to customers. To further address these continuing concerns, the Agencies have published the ANPR. That the Agencies are willing to revisit the issue of clear notice to consumers by considering a short-form notice is an encouraging sign for consumer privacy interests.

Financial Privacy Notices: Shorter is Better


For business, the goal should be not only to provide a notice that satisfies the legal requirement, but one that consumers can easily understand. Although practices may vary from company to company, the bottom line is always the same: Companies either share information with affiliates and third parties or not. Consumers either have the right to opt-out or they don't.

Groups Submit Comments to National Banks Agency Opposing Preemption of States


The OCC's proposed revisions to 12 CFR Parts 7 and 34 of its regulations identify certain types of state laws that would be preempted for non-real estate loans made by national banks.

The scope of the OCC's proposal potentially affects consumer protection and privacy laws of many states. However, we limit our comments to the potential impact on California laws. Particularly troubling is the uncertain implication of the OCC's rulemaking for important identity theft laws that involve access to, and use of, credit reports. Of equal concern is the OCC's proposed regulation to preempt state laws that require national banks to give mandated statements to be included in billing or credit related documents.

Groups Oppose Data Mining of Health Information by Financial Institutions


Today, the Health Privacy Project (HPP), the Electronic Privacy Information Center (EPIC), and 28 other groups, including the Privacy Rights Clearinghouse, sent a letter to U.S. Health and Human Services Secretary Tommy Thompson, opposing any changes to the new medical privacy regulation that would give a green light to banks and other financial institutions to access sensitive, personal medical information. The organizations include health care advocacy, labor, consumer, disability rights, and health care provider groups.

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