OCC 2000-25
Subject: 	Privacy Laws and Regulations
Description: Summary of Requirements	
Date:  September 8, 2000

TO:  Chief Executive Officers and Compliance Officers of All National
     Banks, Department and Division Heads, and All Examining Personnel

The enclosed document, "Privacy Laws and Regulations," is designed to
assist national banks and their subsidiaries in complying with federal
laws and regulations relating to the disclosure of consumer financial
information.

"Privacy Laws and Regulations" focuses on the privacy provisions contained
in Title V of the Gramm-Leach-Bliley Act, including the interagency
regulations with which financial institutions must comply by July 1, 2001,
and the affiliate information-sharing provisions of the Fair Credit
Reporting Act.  These laws contain extensive federal requirements
governing the disclosure of consumer information by banks and other
private entities, and the differing requirements of these laws may be a
source of confusion.  Accordingly, the document seeks to compare and
clarify these requirements, and to identify specific areas of compliance
risk in which satisfying one set of requirements will not necessarily
amount to compliance with the other.

"Privacy Laws and Regulations" also summarizes relevant privacy provisions
of the Electronic Fund Transfer Act, the Right to Financial Privacy Act,
the Children's Online Privacy Protection Act, and other laws.  Like the
Fair Credit Reporting Act, all of these laws are fully in effect, and
financial institutions must be in compliance with them currently.

With respect to the privacy provisions contained in Title V of the
Gramm-Leach-Bliley Act, and the interagency regulations implementing those
provisions, the document notes that senior management and the boards of
directors of national banks and their subsidiaries are strongly encouraged
to ensure that their institutions take all appropriate steps before the
mandatory compliance date so that they are prepared to comply fully with
the interagency regulations at that time.  These steps should include, as
appropriate for the institution:  conducting an inventory of information
collection and disclosure practices, evaluating agreements with third
parties that involve the disclosure of consumer information, establishing
mechanisms to handle opt-out elections by consumers, developing or
revising existing privacy policies to reflect the new regulatory
requirements, determining how to deliver privacy notices to consumers,
establishing employee training and compliance programs, and setting target
dates for all features of the implementation program.

For further information about the matters discussed in "Privacy Laws and
Regulations," please contact Amy Friend, Assistant Chief Counsel
(202-874-5200), Michael S. Bylsma, Director, Community and Consumer Law
Division (202-874-5750), or Stephen Van Meter, Senior Attorney, Community
and Consumer Law Division (202-874-5750).

_________________________________________________     
Julie L. Williams
First Senior Deputy Comptroller and Chief Counsel

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