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WASHINGTON, D.C. — As the two national trade associations representing community banks, we know our members have a long and proud tradition of protecting the privacy interests of their customers. While we appreciate the efforts made by the American Bankers Association and other organizations to craft guidelines that address many bank concerns, particularly those of large banks, we believe that community banks have a unique stake in addressing privacy concerns. Community banks’ most valuable asset is customer trust. Protecting the confidentiality of customer information is as much a part of the business of community banks as taking deposits and making loans — it has to be. The livelihood of community banks is uniquely dependent on the trust that customers place in their local bank. ACB and the ICBA are committed to helping our members preserve that trust, while at the same time ensuring that they can provide a competitive alternative in a world of larger and larger conglomerate financial institutions.

Community banks share information when it helps them better serve their customers. These benefits include faster, more efficient delivery of services; a wider array of the financial products and services customers want and have come to expect from their banks; and enhanced protection against fraud and unauthorized transactions. And they come as the result of information sharing activities between trusted, long-term third-party partners, not just within the family of companies.

Ultimately, the judgment of the American people about whether their privacy interests are being properly protected by their financial institutions will be based more on the actions they see, actions we believe are the embodiment of community banks.

Community banks have safeguarded the personal information of their customers long before there were laws mandating such efforts. Therefore, it is with great confidence that we encourage all of our members to comply with the final rules implementing the new federal privacy law before the required deadline of July 1, 2001. At the same time, federal and state governments should refrain from enacting more restrictive financial privacy laws until the requirements of the Gramm-Leach-Bliley Act can be implemented and its effects assessed.

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Independent Community Bankers of America is the primary voice for the nation’s community banks, representing 5,500 institutions at nearly 16,700 locations nationwide. Community banks are independently owned and operated and are characterized by attention to customer service, lower fees and small business, agricultural and consumer lending. ICBA’s members hold more than $491 billion in insured deposits, $589 billion in assets and more than $344 billion in loans for consumers, small businesses and farms. They employ nearly 232,000 citizens in the communities they serve. For more information, visit www.icba.org.