OCC, FRB, FDIC, OTS, NCUA & FTC: Draft Affiliate Sharing Survey

ABA Contact: Nessa Feddis
Published: 71 Federal Register 51888, 31 August 2006
Comments Due: October 30, 2006
Disposition: Filed


ABA filed a comment letter on the banking agencies' request for comments on a proposed information collection concerning "Survey of Information sharing Practices with Affiliates." Pursuant to Section 214(e) of the FACT Act, the banking agencies are required to conduct regular studies of the consumer information sharing practices by financial institutions. In addition, in accordance with the requirements of the Paperwork Reduction Act, the agencies may not conduct information collection absent OMB review. ABA believes that significant revisions in the draft survey are necessary in order to reflect the variations of information sharing practices. ABA recommends that the agencies consult institutions for their suggestions on re-crafting the questions to capture a more meaningful representation of affiliate sharing practices. The survey should also include definitions of important terms, including: affiliate, consumer, customer, personally identifiable transaction or experience information, purposes related to employment or hiring, the letter said.

2006 Regulatory Chart
ABA Comment Letter
Federal Register