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FACTA / NAID Gov't Relations Work Ongoing

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The submission of NAID’s comments to the FTC by no means marks the end of its efforts regarding the FACTA Disposal Rule. Even though the FTC rule will have the broadest application over the greatest number of businesses, most of which are not affected by any other similar requirement, several other federal agencies with other jurisdictions are also in the midst of FACTA rule making.

Agencies that have put forth their own version of the FACTA Disposal Rule include National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Federal Reserve (FED), Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS). Those falling under their jurisdiction would already be covered by Gramm-Leach-Bliley.

NAID is currently reviewing the proposed rules put forth by these agencies. In general, they each have provided scant guidance on the matter and that will probably be the gist of NAID’s comments. This is in stark contrast to the FTC’s rule that was very clear and provided strong guidance.

Public comments are due to the NCUA by the end of business on July 12, 2004. Public Comments are due to the remaining agencies by the end of business on July 23, 2004.

The NAID Gov’t Relations Committee is also formulating its "post-comment" strategy. Once the Final Rules are published, they become law after 90 days. NAID intends to be ready to "hit the ground running" when this happens.@ There are many ideas including hosting a high-profile reception on Capitol Hill featuring a speech by a well respected author on privacy rights and identity theft.

The Public Relations Committee will in all likelihood be developing a brochure which will be ready for distribution on or before the date that the FACTA Disposal Rule becomes law.