Subject: File No. S7-6-00

Date:    03/20/2000 5:26 AM
     
     
I am a part-time law student at Georgia State University.  One of our 
assignments for Administrative Law is to write comments on a proposed 
agency regulation.  I am writing to give my comments on the proposed 
Regulation
S-P: Privacy of Consumer Financial Information.
     
In G-L-B Act Section 501, the Securities and Exchange Commission (SEC) was 
given the task of
establishing appropriate standards to:
(1) insure the security and confidentiality of customer records and 
information
(2) protect against any anticipated threats or hazards to the security or 
integrity of such records and
(3) protect against unauthorized access to or use of such records or 
information which could result in substantial harm or inconvenience to any 
customer.
     
In addition to establishing standards for the above reasons, the SEC was 
also directed to work with the other named agencies in establishing the 
standards whereby as much as possible the regulations proposed by the 
agencies would be consistent and comparable. G-L-B Section 504(a)(2).
     
The proposed regulation spefically asks for comments on whether the proposed 
definition of "publicly available information" should treat information that 
is publicly as nonpublic if the institution does not obtain the information 
from a listed public source ("alternative definition").  Under G-L-B Act 
Section 509(4)(B), the SEC does have the authority to include the 
alternative definition in the proposed regulation.
 As a consumer,  I would like to see the alternative definition included. 
The purpose of this regulation is to protect consumer's information.  By 
including the alternative definition it is adding one more safeguard to 
protecting the information.
     
It appears that many of the people who have had their response posted on 
the internet are concerned about the Opt-Out provisions in the regulation. 
However, since this was part of the G-L-B Act, it is a proper part of the 
regulation.  As a consumer, I like the fact that you specifically state 
that consumer having to write his or her own letter is not providing a 
reasonable means for the consumer to opt out.
     
Another area of comment is the definition of affiliate not being the same 
for all agencies.  Since the SEC has a reasonable explanation why their 
proposed definition is not the same as the other agencies it appears to be 
proper under G-L-B Section 504(a)(2).
     
The inclusion of examples within the proposed regulation is helpful to 
consumers and to businesses regulated by the proposed regulation.
     
The SEC in this proposed regulation performed the tasks assigned in the 
G-L-B Act and did not exceed its authority in any provision.
     
Sincerely,
Roberta L. Hacker