Joint Letter to Commerce re: Extending Deadline for Comments

October 3, 2018

Via Email: [email protected]

National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, NW
Room 4725
Washington, DC 20230

Re: Request for Extension of Comment Period, Request for Comment, Docket No. 180821780-8780-01

Dear Sir or Madam:

The undersigned financial trade associations appreciate the opportunity to provide comments on the proposed approach on protecting consumer privacy published in the Federal Register on September 26, 2018, the Request for Comments (RFC). However, we believe the deadline for comments should be extended to ensure adequate response.

We agree with your view that the “time is ripe for the Administration to provide the leadership needed to ensure that the United States remains at the forefront of enabling innovation with strong privacy protections.”

This issue is a significant concern for financial institutions. As you are well aware, the financial services sector is already subject to several Federal privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA), among others. As such, we are well acquainted with the need to protect the privacy of consumers and expend substantial resources to achieve that end. Naturally, we firmly believe that the need for privacy protections must be considered in the context of the existing and well-founded standards as well as the effective functioning of the financial system.

The issues raised in the RFC are vitally important to our sector as well as the broader U.S. economy, and they deserve our serious attention. In that regard, we need sufficient time to solicit the views of our respective members and provide thorough comments on your proposal. Therefore, we request the Department provide an additional sixty days for comments on the RFC.

Respectfully submitted,

American Bankers Association
Consumer Bankers Association
Securities Industry and Financial Markets Association