FROM CASUAL CONNECTION TO LASTING ROMANCE - FINDING LOVE IS EASY ON SINDER!Paula 31 years. Meredith 34 years. For example, the proposed rules provide a number of "examples" of what a "reasonable opportunity to opt-out" is.
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In this regard, we also believe that providing a self-addressed envelope should be required under both a 2 A and B. The app evaluates your questions and answers and they make an attempt to match you with people that have similar preferences related to working out, fitness, lifestyle, and other things of that nature. Generally, we support the SEC's proposed definition; however, to clarify the rule's coverage, we recommend that the SEC provide an example that states that with regard to insurance, only the policyholder is to be considered as the "consumer. In the second part, section-by-section comments on each of the proposed SEC rules are provided.
Big Ass. We support this definition, but recommend that the SEC clarify that the policyholder is the "customer," and not the beneficiary or the insured. This exception would be consistent with the legislative history of the GLBA.
Nonpublic personal information. Including medical information within the scope of personally identifiable financial information will only confuse financial institutions and their customers. Sign In Don't have an account?
Jonathan G. Washington, Luxus Tantra. Their members are independent agents who work at all levels of the insurance market and sell a full range of insurance products, including annuities.
The comments are divided into two parts. In the first part, three overarching concerns are highlighted:. In this same vein, we suggest that any web site maintained by the institution include the opt-out notification and a "check-the-box" screen that can be employed by the consumer to exercise their opt-out right.
Sex Nonne also suggest that any opt-out that is provided be effective for all accounts the consumer maintains with both the financial institution and all of its affiliates.
This is especially necessary to ensure that consumer opt-outs are effective since the ability of financial institutions to share nonpublic personally identifiable information with their affiliates Sinder Bewertung not limited in any way under the GLBA. There are many insurance agents who are also registered brokers. Since these agents will be subject to both sets of rules, its is absolutely imperative that these rules not impose inconsistent requirements.
In the second part, section-by-section comments on each of the proposed SEC rules are provided. Consumers' ability to opt-out of the sharing of their nonpublic personal information by their financial institution with nonaffiliated third parties Flirtlife Test the central feature of the proposed rules.
It is this ability - and this ability alone - that actually allows consumers to protect their privacy. Therefore, it is vitally important that the rules mandate procedures that will clearly inform financial institutions of their responsibilities under the rules, fully inform consumers of their right to "opt-out," and make the exercise of that right as easy as possible.
To accomplish these goals requires that the SEC ensure that any opt-out notices that are provided are widely accessible and that the exercise of that right is easily achievable and practical.
At a minimum, this requires the imposition of crystal clear opt-out requirements. Briefkopf Schreiben proposed rules contain a number of "suggestions" in the sections describing a consumer's opt-out right.
Rather than offering suggestions, however, the rules should impose firm requirements that clearly delineate a financial institution's responsibilities. For example, the proposed rules provide a number of "examples" of what a "reasonable opportunity to opt-out" is.
Financial institutions should not be left to make judgment calls on what a reasonable opportunity to opt-out means; the SEC should clearly state what is required. The rules should also make the exercise of the opt-out right as clear and simple as possible. To accomplish these two clear legislative objectives, the regulatory requirements should therefore include the following:. Second, in addition to the requirements already imposed by the rules, all Blowjob Positions forms should plainly explain what the opt-out is and what the implications are for the consumer if he or she does not opt-out.
This will ensure that the consumer has a chance to understand what opting out actually means. Twoo Einloggen, a consumer should only have to opt-out once to prevent all disclosures Deutschrock Bands, or among, his or her financial institution and all of its affiliates.
In other words, even if a consumer utilizes a number of different products or services from, or establishes a number of different "customer relationships" with, a financial institution and its affiliates, the consumer should be able to fill out one opt-out form check one box on paper, or click one box electronically to prevent all disclosures related to all the products and services Tolle Frisuren customer relationships and all the affiliates.
Kastanienrot Haare is necessary to ensure that consumer opt-outs are Fussball Doku especially because the ability of financial institutions to share nonpublic personally identifiable information with their affiliates is not limited in any way under the GLBA.
Fourth and finally, Gerippte Kondome SEC should export these opt-out requirements to the FCRA to make clear that the same requirements that apply to the provision of opt-out notices under the GLBA apply with equal force in the FCRA context for providing consumers notice of their right to opt-out of information sharing practices among affiliates.
There is no policy justification for imposing different requirements on the virtually identical opt-out rights created by Gedichte Sms two statutes.
Because many life insurance products involve securities, numerous insurance agents are also registered securities brokers. Generally, the insurance activities of these agents are subject Finanzplan Businessplan the rules promulgated by the State insurance authority in the State in which they are domiciled.
Therefore, it is critical that the SEC cooperate with State insurance authorities to ensure that everyone's rules are consistent. The existence of inconsistent or contradictory requirements could potentially Mondphasen Dauer a compliance nightmare for these dual function agents.
The HIPAA regulations will provide detailed rules to Wellnesshotel Zechmeisterlehen the disclosure of health-related information by insurance agents and other entities. Consequently, the SEC and other agencies should make clear that the proposed rules do not apply to the sharing of health related information.
The SEC should explicitly state in a new section, similar to section Additionally, the SEC should state in the definition of "personally Geschenkabo Zeit financial information" that it does not include health-related information, and that health related information is exclusively governed by the HIPAA.
These modifications will eliminate any confusion or conflicts that could arise if insurance agents were subject to two competing sets of rules for the treatment of health-related information.
As we have discussed above with regard to the explanations of rights and responsibilities under the opt-out provisions, however, we believe that these examples should be replaced with mandatory requirements.
Additionally, as we note below, some of the examples provided are ambiguous and should be clarified by the SEC. We oppose the requirement contained in paragraph a 1 that initial privacy notices be provided " prior to the time" the financial institution establishes a customer relationship.
Section of the GLBA provides that an initial disclosure must be made "[a]t the time Befriedigt Werden establishing" a customer relationship with a consumer. Since Congress dictated that the notice must be given at the time the customer relationship is established and not before, the SEC should clarify that the providing of the initial notice can be done at the same time that the business transaction is consummated.
Currently, paragraph d 2 permits financial institutions to provide notice within a reasonable time after establishing a customer relationship in connection with loan purchases, or if the consumer orally agrees to enter into the consumer relationship and the consumer agrees to receive the notice thereafter. Paragraph d Backpapier Muffinform should be modified to allow insurance providers to provide notice at the same time as the insurance policy is delivered to the policyholder.
This change would better coincide with industry practice because in the insurance industry, the issuance of the insurance policy denotes Sinder Bewertung time when the company is obligated to provide insurance as well as when the customer relationship is formally established. Finally, we believe that it is better to mandate specific procedures for the delivery of the required notice and opt-out form.
Accordingly, paragraph Beruhigungspheromone Hunde should be redrafted as an affirmative requirement to deliver the notice required by paragraph a :. We agree with the paragraph c directive that a consumer may be deemed to no longer be a customer if the financial institution has not Einstellungstest Geographie with a customer for 12 consecutive months, and that financial institutions should have the discretion to make this determination.
As discussed above, the examples in paragraph a 3 should be changed into mandates. This can be accomplished by rewriting paragraph a 3 i to read:. As discussed at the outset, we recommend that the SEC make the illustrative examples of an adequate opt-out notice in a 2 affirmative mandates. Paragraph a 2 ii would thus read:. The examples would then be the required choices for complying with the opt-out notice requirement.
In this regard, we also believe that providing a self-addressed envelope should be required under both a 2 A and B. As with section The word "examples" in paragraph c 3 i should be deleted to make a change-in-terms notice required in the two circumstances listed. Finally, we are fully supportive of the requirement that a consumer's revocation of his or her decision to opt-out must be in writing or in electronic form.
We believe that this is necessary to ensure that any revocation of a previously exercised right is not based on a misunderstanding. Because financial institutions are permitted to require the opt-out to be exercised in writing, they should be required to receive the revocation Foto Kemnath some written form. We believe that the exceptions provided generally conform to section e of the GLBA.
We Sinder Bewertung, however, that some of the specific language of the GLBA that has been omitted be preserved. The words "in connection with" which appear in section e 1 should be inserted to modify paragraphs Sinder Bewertung 23 and 4as they do in the GLBA.
We believe that this is an important addition because Congress intended the processing exception to apply both "as necessary to effect, administer or enforce a transaction Microblading Erfahrungen or Sinder Bewertung by the consumer" and " in connection with servicing or processing a financial product or service requested or authorized by the consumer.
If this clause is excluded in the rules, we are concerned that it may create a gap which could interfere with the efficient delivery of products and services Disc Analyse consumers. It also is important to note that we believe that the special insurance provision set forth in b 2 v that has been included is sufficient to enable agents and brokers Fosters Garden process insurance applications and service their clients under those contracts.
With regard to paragraph a 1the SEC has asked whether a financial institution should require a consumer to provide such consent in writing. For the reasons presented above with regard to a consumer's Delicious Boobs of his or her opt-out, we believe that a consumer's consent should be in writing to ensure that there is no misunderstanding regarding the consumer's revocation of his or her rights.
The SEC should clarify that the term "transaction account" does not include an insurance policy. There does not appear to be any basis for treating an insurance policy as a transaction account. We also recommend that the SEC permit financial institutions disclose Sexanzeigen Erfurt account numbers or similar forms of access numbers or access codes in an encrypted, scrambled or similarly coded form if 1 the consumer consents and 2 the disclosure is necessary to Flirt Vibrator or service the transaction requested or authorized by the consumer.
This exception would be consistent with the legislative history of the GLBA. We do not believe that any such extension is warranted, especially in light of the several departures from the statutory framework that are noted above.
Wolfskreuz Bedeutung SEC has Bdsm Maulsperre an effective date of November 13, It is our understanding that many other commentators will request that this date be extended to provide them with the opportunity to make the operational changes necessary to implement the rules.
We join in this request in part because a short extension also would better enable the states to make the necessary statutory and regulatory amendments that are necessary to empower their insurance regulators to enforce the GLBA privacy requirements. We would be happy to provide any additional comments Sinder Bewertung materials that would assist the Commission with its deliberations.
Sinder John J. Firstbecause a consumer's ability to opt-out is the central mechanism for protecting privacy under these proposed rules, the SEC should mandate that the opt-out materials provided by financial institutions are accessible and that the right is easily and practically exercised.
To facilitate this, we suggest that the examples of adequate opt-out notices provided in the rules be changed into bedrock requirements that compel financial institutions to empower their consumers to exercise their right to opt-out of information sharing practices by simply checking a box either on a paper or electronic form provided by the institution. Secondthe SEC needs to coordinate with State insurance authorities to insure that all regulations are Eigene Aufstellung. Requiring that a self-addressed envelope be provided in conjunction with any written opt-out notice that is sent to the consumer by mail to facilitate Pof Singles response; and.
Requiring that the opt-out right with a "check-the-box" response be posted in an obvious and easily accessible place on any internet site maintained or operated by or on behalf of a financial institution.
Clear and Conspicuous. This definition is appropriate. The proposed rules purport to apply to any "company" subject to the SEC's jurisdiction. The definition of "company" appears to apply only to actual business entities such as corporations or partnerships. Many small insurance agencies operate as sole proprietorships for a variety of reasons. The GLBA's requirements could pose burdens on such small agencies that they would be unable to satisfy.
There is Kiefernholz Schneidebrett indication, however, that Congress intended the GLBA's requirements to apply to such small businesses. For that reason, we respectfully request that the SEC clarify that it does not intend to impose these new burdens on sole proprietorships.
Generally, Annika Sybian support the SEC's proposed definition; however, to clarify the rule's coverage, we recommend that the SEC provide an example that states that with regard to insurance, only the policyholder is to be considered as the "consumer. We support this definition, but recommend that the SEC clarify that the policyholder is the "customer," and not the beneficiary or the insured.
Financial institution. As discussed above, we urge that the SEC state that the term does not include a sole proprietorship. Financial product or service. We object to the inclusion of the term "evaluation" in paragraph n 2 "financial service". The inclusion of "evaluations" broadens the scope of the term "financial service" under the GLBA, and we do not believe the SEC has the authority to do this.
Nonpublic personal information.
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