The information on this Website on comments submitted to the Treasury Dept on information sharing practices is very interesting. Most commenters certainly have presented financial institution's practices in a most unfavorable light. Our trade associations should have a grassroots campaign to change the public's perception of us...and educate the public on information sharing.

I couldn't agree more!

Dear Anonymous Banker--

As a former employee of a banking trade association, let me just say that you are off base. The trade associations cannot just "have a grassroots campaign to change the perception." The definition of grassroots is "people at a local level rather than at the center of major political activity." This means that you as a banker are a necessary ingredient to a grassroots campaign. The association where I worked always thought that grassroots campaigns worked best. However, when we tried to do a grassroots campaign, we got the same 60 or so volunteers every year--and most of them were not interested in spending much time at it. So, if you want a grassroots campaign, call your state's association and tell them that you want it and that you are willing to take a "working" position on the campaign. Otherwise, you can do like most of your fellow-bankers do-sit on the sidelines and then when the banks get hammered in the press, by consumers, or by regulators, complain that the associations don't do enough.

While sitting on the "sidelines" I am fielding calls from branch staff who have a customer at their desk and want to know "what to do", responding to management about why we can't offer a particular loan product only to individuals with a certain level of income, performing branch audits, writing policies and procedures, sitting through endless meetings, and constantly reading and re-reading alerts, bulletins, legal opinions and regs just to make sure I know what I am doing. It isn't that I am lazy and want my state association to do all the work on my behalf. It's that I am so weighed down with the day to day responsibilities of my job, it's difficult to find the time to "volunteer". That's why I do rely on my state association to look at the big picture for me. I don't think it unreasonable to hope that our state associations have their finger on the pulse of banking related activites and to act on our behalf. I have a good working relationship with my association and I would be surprised if they would consider myself or anyone else to be just "sitting on the sidelines".

No one said you weren't very busy, but if you don't take the time to get involved politically, don't cry when you lose regardless of the efforts of the paid, registered lobbyists at your association

You misread my email or just decided to take an aggressive stance without consideration of the content. The original post asked for a grassroots effort by the associations. By definition this is impossible. A grassroots effort has to take place on a local level. Your association can initiate such an effort and provide resources, but ultimately a "grassroots" effort has to be done by the bankers themselves. If you think that the associations can do it themselves or you depend on them to do it, you will lose just about every time.

The Know Your Customer Rules did not die a couple of years ago because of the efforts of the associations. It died because of a grassroots uprising. The regulators would have blown off the associations' reasonings against KYC as partisan bias. But the bombardment from the local level convinced them otherwise.

The credit unions are not so successful at expanding their powers because their associations are so much smarter than the bankers' associatons. They are successful because when there is an issue in DC, thousands of them show up and tens of thousands of them give money to their PAC. I have seen how legislators when faced with the fact that credit union customers are actually more affluent that bank customers, agreed that the membership should be restricted. During the same legislators brazenly asked where the votes would come from when he was up for reelection. We knew the answer--from the thousands of credit union members out in the streets of DC storming the congressional offices. The battle was lost before it was even fought.

I am not trying to make this a credit union vs. bank issue. I don't have a dog in that hunt anymore, but it is a great example of how grassroots politics works. The credit unions do it very well--they get their members excited and riled up. Then they turn up in large numbers to voice their opinions. The legislators see them as constituents who vote. They see the association folks as paid registered lobbyist...which is what they are. Lobbyist can have influence and can communicate your side of the issues, but in the face of a loss of votes for reelection, they will not be given serious consideration.

You may be thinking that dollars speak to legislators also. Well, the credit unions are another great example of a grass roots effort. Their members donate millions of dollars. Call your association--I bet the credit union association in your state has much, much more money. CUs raise money at a grassroots level as well as any PAC this side of the NRA.

So, please read the original post and my response and you will see that my response was well reasoned and, well, accurate. Having your pulse on banking related activities and being successful in influencing them for your constituency are two totally different things. Ask your association and if they are honest, they will tell you the same thing--"We can't do it without your help." The original poster was right, but I think he or she misunderstands what "grassroots" really is.

Were the rest of you as appalled as I was that the way the regulators posted the comment letters on their Web site shows emails addresses on the ones that were submitted via email and home/business addressess on the ones that came through regular mail? That just is so bizarre when the issue is privacy and information sharing. Treasury just shared with spammers and everyone else personal information about people who are obviously very concerned about privacy issues.

For those of you who don't get the Banker Briefings and missed our article, you can link to it here:

Information Sharing: What Consumers REALLY Think

Yes, I was very surprise to see that. The fact that they did not remove the personal info is really scary - names, email addresses and phone numbers should not have been made available on the net. After seeing that I am afraid it will have an opposite effect - people will not respond to requested comment topics...

I believe the request stated that the letters or emails would be made publically available, to me this meant the entire letter. That is why I did not make a comment on the issue. Perhaps they need to pass a law restricting the public use of information by the Government after all that is the only solution to every issue right!?!

Texas passed such a law just last year. Senate Bill 694, enacted in the 77th Legislative session (2001), added §§ 552.136 and 552.137 to Government Code Chapter 552, entitled "Public Information." Section 552.137 provides that an email address of a member of the public, that is provided for the purpose of communication electronically with a governmental body, is confidential and not subject to disclosure under open records requests.

Not to beat a dead horse. And I don't mean this to pick on you, but the bankers who do quite a bit of volunteer work for their associations are a little insulted when other bankers say they are too busy to serve on a committee or participate in a grassroots effort. They are insulted because they are busy too and feel like those who say they are too busy are essentially saying, "I have so much more work to do than you folks who are volunteering."

The truth is not that those refusing to volunteer are busier than those who volunteer. The truth is that those who volunteer are probably the busiest of all--but they also see the importance of volunteering. Check it out--I bet that many of the volunteers at your association are the bankers who are on the cutting edge and are doing much work to expand their markets, etc....

Now that I've gotten older, I have a little different perspective on the volunteer issue. What I've seen over the years is that people go through different phases in their lives and activities take on different priority levels depending on a variety of factors. Someone's job duties may be a small part of the pressure/time constraints they're under, caring for elderly parents, renovating a home they just bought, rearing children (who they don't want to have grow up to be happy face mail bombers).

To each his own.

But for those who DO get involved as a volunteer, the rewards (nonmonetary) can be great. I have thoroughly enjoyed serving on the editorial board for the ABA Bank Compliance magazine over the last few years, for example. You meet great people, gain insight into what goes into an endeavor of that type, and feel like you're doing something positive to contribute to the industry.

As it pertains to information provided about comment letters, this is just the second verse of the same song.

We have heard so much in the last few years about the invasion of privacy, but no invasion existed. Information was publicly available in the past, but was difficult to use cost effectively. When the same records were available electronically, it became cost effective and useful.

If you may go to the FRB and view comment letters, uncensored, then why should there be additional restrictions on what is supposed to be the same information available on the Web? The answer is, there shouldn't be. Only now, the likelihood of someone seeing it is greater.

I am not saying it is right, certainly it is ironic that this is a privacy issue, but the two methods should be the same, censored or not.

But you're not a very busy person, right?