Copyright 1999 Federal Document Clearing House, Inc.
Federal Document Clearing House Congressional Testimony
July 21, 1999
SECTION: CAPITOL HILL HEARING TESTIMONY
LENGTH: 5530 words
HEADLINE:
TESTIMONY July 21, 1999 L. RICHARD FISCHER HOUSE BANKING AND
FINANCIAL SERVICES FINANCIAL INSTITUTIONS AND CONSUMER CREDIT UNIONS FINANCIAL
PRIVACY
BODY:
WRITTEN STATEMENT OF L. RICHARD
FISCHER ON BEHALF OF AMERICAN BANKERS ASSOCIATION CONSUMER BANKERS ASSOCIATION
THE FINANCIAL SERVICES ROUNDTABLE VISA U.S.A. BEFORE THE FINANCIAL INSTITUTIONS
AND CONSUMER CREDIT SUBCOMMITTEE OF THE COMMITTEE ON BANKING AND FINANCIAL
SERVICES U.S. HOUSE OF REPRESENTATIVES JULY 21, 1999 Chairwoman Roukema and
Members of the Subcommittee, my name is L. Richard Fischer. I am a partner of
Morrison & Foerster and practice in the firm's Washington, D.C., office. I
am appearing today on behalf of the American Bankers Association ("ABA"),(1) the
Consumer Bankers Association ("CBA"),(2) The Financial Services Roundtable (the
"Roundtable"),(3)and Visa U.S.A. ("Visa").(4) For nearly three decades, I have
advised a variety of banks and other financial service providers across the
United States and internationally on regulatory and retail banking matters,
including those related to privacy. In addition, I am the author of the leading
treatise in this field, entitled The Law of Financial Privacy, which is now in
its third edition. We commend you for holding today's hearing, and appreciate
the opportunity to appear before the Financial Institutions and Consumer Credit
Subcommittee ("Subcommittee") of the Committee on Banking and Financial
Services, of the U.S. House of Representatives, to discuss the on-going efforts
of financial institutions to protect consumer privacy. Today, we are living
through an information revolution and, as a result, are witnessing the
development of new data management technologies that permit the assembly,
storage, analysis and sharing of vast amounts of information. Although this
information revolution is by no means limited to banks, within the financial
services world, the resulting efficiency permits banks to offer consumers
unparalleled choice of financial products and services, while simultaneously
diminishing the number of unwanted offers. Understandable concerns about the
collection and use of personal information by commercial firms have launched an
open and dynamic discussion about the appropriate balance between the adequate
protection of individual privacy and the fair use of
personal information. Banks, for their part, are devoting
significant resources to achieving this balance. In the course of addressing the
Subcommittee's specific questions, my testimony today will focus on four key
themes. First, I will describe the fundamental principle of customer
confidentiality upon which banks have relied historically, and continue to rely,
for their very success. Second, I will discuss the importance of information
sharing to the modern American economy in general and to the banking industry in
particular. In so doing, I will provide specific examples of the need for, and
the benefits to consumers from, information sharing by financial institutions. I
also will describe the significant adverse consequences both for consumers and
banks which could arise from significant new information sharing restrictions.
Third, I will underscore a critical point that is repeatedly overlooked in many
of today's privacy debates: the fact that existing law already regulates
information sharing and provides consumers with numerous privacy protections.
Finally, I will discuss on-going banking industry efforts to protect consumer
privacy, which are vibrant and effective. As a result, I will express my belief,
and that of ABA, CBA, the Roundtable and Visa, that the existing legal framework
which governs the sharing of information by the banking industry provides
effective consumer privacy protection, while permitting the flow of information
that is vital to the banking industry and to the U.S. economy as a whole. Given
this framework, consumers today have unprecedented access to, and information
about, a universe of products and services which could only have been imagined
just a few years ago, while retaining the ability to express and enforce their
reasonable expectations of privacy. Maintaining the Confidentiality of Customer
Information is a Banking Industry Cornerstone Financial institutions have a long
history of successfully balancing the need to maintain personal information to
serve the financial needs of and identify opportunities for their customers,
with the privacy concerns of those customers. Banks historically have recognized
that personal information about bank customers should be protected, and
consequently have developed strong, internally-initiated safeguards to ensure
the confidentiality and proper use of customer information. Given the special
relationship they share with their customers, banks are particularly well suited
to protect consumer privacy in the electronic commerce age. Although the form
and quantity of information may have changed, it is a change in degree, not in
kind. The fundamental operating premise of banks -- that to be commercially
viable, they must protect their customers' privacy - - extends to new financial
services holding companies which, under H.R. 10, will be able to offer an
expanded range of products and services to consumers. These financial
institutions understand that although their products may be highly innovative,
their operating principles must remain traditional -- that is, the protection of
consumer privacy is, and will remain, the cornerstone of successful banking. The
fact is, the marketplace works. Market-driven dynamics and an ever-increasing
public focus on privacy compel each individual bank to respect the privacy
wishes of its customers. Stated another way, protecting privacy is not only the
right thing to do, but is critical to the commercial success of every financial
institution. The banking industry is subject not only to continuous government
oversight, but also to close scrutiny by the media and the public. Particularly
given the intensely competitive nature of these industries, no bank can thrive,
or perhaps even survive, for long should it gain a reputation for indifference
about the confidentiality of customer information. Consequently, although the
increased availability of consumer information in the modern era enables banks
to provide consumers with increasingly diverse product and service
opportunities, the use of such information is necessarily balanced with the
fundamental commitment of banks to maintain the privacy of
personal customer information. In fact, the protection
of privacy is increasingly becoming a separate product
characteristic, on which consumers shop for products and services, and banks
compete for customers. Today and into the foreseeable future, consumers have and
will continue to have the ability to choose among a tremendously diverse group
of financial institutions -- including community banks, institutions offering
only traditional deposit and loan services, and diversified institutions
offering a growing array of financial services. Moreover, recent experience
demonstrates that the marketplace is vigorous, and that even the suggestion of a
market failure with respect to privacy is rapidly addressed. The American public
is both sensitive to and vocal on privacy issues, and the marketplace has
responded with alacrity to public privacy concerns. This fact was powerfully
demonstrated by recent widely-publicized events in which financial institutions
quickly reexamined and promptly curtailed the communication of personal
information to third parties for certain marketing purposes in direct response
to expressions of concern by the public, the press, and federal and state
regulators. Furthermore, the banking industry generally -- and ABA, CBA, the
Roundtable and Visa in particular -- has been supportive of addressing market
failures through legislative action, when appropriate. For instance, the banking
industry has actively supported Congressional efforts to address privacy issues
relating to identity theft, illegal information brokers and pretext calling. It
also is important to note that many of the existing consumer privacy protections
have arisen not out of government intervention, but out of market-driven
business principles that compel banks to value and protect consumer privacy. Of
course, the confidentiality of bank customer information receives additional
protection through a variety of federal laws and regulations (some of which I
discuss in more detail later in this testimony), as well as through the internal
policies and procedures of individual banks. Nevertheless, these laws and
regulations are primarily procedural in nature, and are designed principally to
facilitate the smooth functioning of the market. Information Sharing is Critical
to the U.S. Economy and to the Banking Industry The importance of information
sharing to the modern American economy cannot be overstated. Many experts
attribute the unparalleled strength of the U.S. economy in large measure to the
efficient availability of information and the extraordinary investment of U.S.
industry in burgeoning information technologies. For instance, in a recent
speech, Federal Reserve Board Chairman Alan Greenspan observed that information
technologies have begun to alter the manner in which we do business and create
value, often in ways not readily foreseeable even five years ago. . . . Prior to
the advent of what has become a veritable avalanche of IT innovations, most of
twentieth century business decisionmaking had been hampered by limited
information. . . . Large remnants of information void, of course, still persist
and forecasts of future events on which all business decisions ultimately depend
are still inevitably uncertain. But the recent years' remarkable surge in the
availability of real-time information has enabled business management to remove
large swaths of inventory safety stocks and worker redundancies, and has armed
workers with detailed data to fine tune product specifications to most
individual customer needs.(5) With respect to the importance of consumer data to
the American economy, Chairman Greenspan writes, "the plethora of information on
the characteristics of consumers" has been a "critical component of our ever
more finely hewn competitive market system."(6) Greenspan further explains that
" s uch information has enabled producers and marketers to fine tune production
schedules to the ever greater demands of our consuming public for diversity and
individuality of products and services. . . . It has enabled financial
institutions to offer a wide variety of customized insurance and other products.
Detailed data obtained from consumers as they seek credit or make product
choices help engender the whole set of sensitive price signals that are so
essential to the functioning of an advanced information based economy such as
ours."(7) As Chairman Greenspan's statement shows, information sharing is
particularly important to the financial institution sector of the American
economy. Information sharing is essential to the ability of financial
institutions to meet the ever-increasing consumer demand for the efficient
provision of innovative, individually- tailored financial products and services.
For instance, information sharing permits financial institutions to outsource
many basic business operations -- such as customer account servicing, records
administration, auditing, check-printing, and compliance functions -- to third
parties, who perform these operations on behalf of financial institutions. These
third-party specialists typically perform such services more efficiently, and at
a lower cost, than the institution itself might, serving consumers in the most
cost-effective and efficient way possible. Moreover, particularly with respect
to smaller institutions, such as community banks and credit unions, outsourcing
such functions enables institutions to offer products and services to consumers
that the institution otherwise simply would not have the capacity or expertise
to offer. In this way, the ability to share information and outsource banking
operations heightens efficiency and promotes competition in the financial
services sector, to the ultimate benefit of consumers. In addition, information
sharing is critical to a financial institution's ability to control risk and
combat fraud. When, for instance, a bank discovers that it has been defrauded by
one of its customers, information sharing allows the bank to promptly inform its
mortgage or credit card affiliates of the fraud, which dramatically reduces the
chances of the fraudulent operator perpetrating the same scheme on those
affiliates. Similarly, when a bank customer reports that a wallet or purse has
been stolen, information sharing permits the bank to inform the affiliates and
other parties so that they may prevent fraudulent or unauthorized account
activity. Thus, any restrictions on the ability of financial institutions to
share information for fraud and risk control purposes could threaten the very
safety and soundness of insured financial institutions. In this regard, it is
worth noting that federal authorities have long understood the potential
benefits of information sharing with regard to fraud and other law enforcement
activities, and the banking industry has worked with the government to achieve
an information-privacy balance. The banking industry is subject to a number of
reporting requirements relating to the prevention of fraud and related
activities, including the requirement that financial institutions share certain
information -- including currency transaction and suspicious activity reports --
with law enforcement and other government authorities to combat criminal
activities such as money laundering. While the banking industry has generally
supported government efforts directed at fraud prevention, we also have
frequently raised concerns about the various mandates crafted to address that
worthy goal. These requirements create a constant dilemma for the banking
industry: how to balance our obligations to identify and report illegal
activities, while also protecting the privacy of customer financial records. In
addition, information sharing allows banks to improve services in countless ways
that benefit consumers. For instance, information sharing permits financial
institutions to offer consumers the convenience of "one-stop shopping," so that
a bank customer can, through a single monthly statement or in a single telephone
call, obtain information and make decisions about his or her checking account,
mortgage loan, credit card account or other financial relationships of the
customer with the bank and its affiliates. Otherwise, consumers would be forced
to receive multiple statements, or to make multiple telephone calls, to deal
separately with each type of account -- a costly and inefficient result for
consumers and financial institutions alike. Information sharing also permits
consumers to receive lower rates on a variety of products and services offered
by financial institutions. For instance, information sharing permits operation
of the secondary market in home mortgage and other loans, which provides
consumers with significantly lower interest rates that may save the consumer
thousands of dollars over the life of the loan. The ability to share information
also allows a financial institution to offer reduced rates and fees to a
customer of the institution's affiliate, permitting consumers and institutions
to benefit from the inherent efficiencies of so-called "relationship banking."
For example, the savings provided to consumers by the lower interest rates which
result from the secondary mortgage market may be even greater for consumers who
choose to link their mortgage loan with a checking or savings account at the
lender's affiliate. Information sharing also enables financial institutions to
offer consumers popular products such as "affinity" or "co-brand" credit card
accounts. Such programs provide frequent flyer miles, grocery or gasoline
rebates and other benefits to credit cardholders. Other such programs permit
universities and other not-for-profit organizations to benefit from cardholder
use of their accounts. These programs simply could not operate without the
sharing of information between the credit card issuer and the unaffiliated
"affinity" or "co-brand" partner, with whom the consumer also has an existing
relationship which is separate from, but related to, the consumer's relationship
with the financial institution. Moreover, as Federal Reserve Board Chairman
Greenspan has noted, information sharing permits financial institutions to offer
products and services that are more closely tailored to consumer needs and
desires, dramatically increasing efficiency both for banks and consumers.
Finally, the ability to share information has enabled financial institutions to
develop and offer consumers an astonishing array of financial products and
services, which provide consumers today with unparalleled choice, convenience
and opportunity. Consequently, additional restrictions on the flow of
information to and among U.S. companies -- particularly financial institutions
-- could have severe unintended consequences for the U.S. economy, consumers and
the banking industry. New information- sharing restrictions would harm consumers
by restricting, or denying altogether, the availability of the various products
and services discussed above, as well as of countless other offerings. Moreover,
the enactment of new information-sharing restrictions would inevitably have
adverse consequences for the development of increasingly innovative offerings.
In particular, the establishment of new restrictions could stifle, or even halt,
the burgeoning development of new products and services, thereby harming
consumers and banks alike. As Federal Reserve Board Chairman Greenspan has said,
"Given the high degree of uncertainty inherent in the development of new
products and processes, policymakers should be cautious when attempting to
anticipate the future path of innovation, or the effects new regulations may
have on innovation. . . . Incentive compatible regulation, flexibly constructed
and applied, is the logical alternative to an increasingly complex system of
rigid rules and regulations that inevitably have unintended consequences,
including possible deleterious effects on the innovation process."(8) With this
statement in mind, I want to touch on the privacy provisions that are contained
in Subtitle A of Title V of H.R. 10 as passed by the House of Representatives,
about which the Subcommittee has requested comment. The privacy provisions of
H.R. 10 contain a number of unprecedented and sweeping information-sharing
restrictions. For instance, H.R. 10 would establish a comprehensive notice and
opt-out requirement for the sharing of customer information with unaffiliated
third parties, institute a flat prohibition on disclosure to unaffiliated third
parties of customer account numbers for specified marketing purposes, and
mandate the provision of extremely detailed privacy disclosures at the beginning
of a customer relationship and, thereafter, annually. ABA, CBA, the Roundtable
and Visa are fervently committed to addressing privacy concerns that may arise
from the reforms of H.R. 10. We believe, however, that a number of technical
clarifications and corrections to the H.R. 10 privacy provisions are necessary
in order to avoid significant adverse unintended consequences which would result
from these provisions as approved by the House. Moreover, if Congress determines
to enact the privacy provisions contained in H.R. 10, ABA, CBA, the Roundtable
and Visa believe it is absolutely essential that they be enacted as the uniform
law of the land, so that the same requirements will apply to all financial
institutions, and the same protections will be afforded to all consumers,
throughout the country. Existing Law Already Regulates Information Sharing and
Provides Consumers with Extensive Privacy Protections I now want to underscore a
critical point that is often overlooked in many of today's fervid privacy
debates. The fact is, existing federal law already regulates information sharing
and provides consumers with a plethora of privacy protections. Given time
constraints, I will discuss briefly just a handful of the federal laws that play
principal roles in regulating information sharing by financial institutions and
others: the Fair Credit Reporting Act(9) ("FCRA"), the Electronic Fund Transfer
Act(10) ("EFTA"), the Right to Financial Privacy Act of 1978(11) ("Financial
Privacy Act"), and the Telephone Consumer Protection Act of 1991(12) ("TCPA").
The Fair Credit Reporting Act The FCRA mandates that, before non-experience
consumer information is shared among affiliated companies, consumers must be
clearly and conspicuously informed of the possibility of that sharing and be
provided an opportunity to opt out of the sharing arrangement altogether.(13) In
other words, under the existing FCRA, if a consumer does not want his or her
application information or other personal information obtained from third
parties, such as credit bureaus, shared among affiliated companies, the consumer
is empowered simply to prohibit the sharing of that information. Moreover, it is
important to note that the FCRA allows only affiliated companies to share such
application or credit bureau information, after provision to the consumer of
notice and an opportunity to opt out. If a bank were to share such information
with unaffiliated third parties, the bank could become a consumer reporting
agency subject to burdensome, complex and onerous requirements of the existing
FCRA. Moreover, the FCRA mandates that other notices be provided to consumers in
connection with the use of shared consumer information. For example, the FCRA
already requires that banks notify consumers when adverse action is taken in
connection with credit, insurance, or employment based on information obtained
from an affiliate. This affiliate-sharing adverse action notice must inform the
consumer that he or she also may obtain the nature of the information that led
to the adverse action simply by requesting that information in writing. Once
such a request has been made, the bank affiliate then has 30 days to respond by
disclosing the nature of the affiliate information used. In addition, the FCRA
currently empowers consumers by providing them with choice about how consumer
reporting agencies may use their information for so-called "prescreening"
purposes. Prescreening is the process in which a consumer reporting agency
prepares a list of consumers who, based on the agency's review of its files,
meet certain criteria specified by a creditor who has requested the
prescreening. In addition to providing the consumer with a firm offer of credit,
the FCRA also mandates that banks include prescreening disclosures with every
written solicitation to consumers explaining that the offer results from a
credit bureau prescreen and that the consumer has the right to opt out of future
prescreening by notifying the credit bureau that created the prescreened list.
Under the FCRA, a credit bureau that operates on a nationwide basis also is
required to operate a joint system with other nationwide credit bureaus that
allows consumers to opt out of future prescreening by all such bureaus. The
Electronic Fund Transfer Act The FCRA, however, is not the only existing federal
law currently mandating that disclosures be made to consumers in connection with
information sharing activities. For instance, the EFTA and its implementing
Regulation E(14) currently require that consumers be informed about a financial
institution's information- sharing practices with regard to all accounts that
may incur electronic fund transfers ("EFTs"), which today includes virtually all
checking, savings and other deposit accounts. Specifically, Regulation E
requires that a financial institution provide consumers with extensive
disclosures at the beginning of the consumer's EFT relationship with the
institution.(15) As part of these initial disclosures, each financial
institution already must state the circumstances under which the financial
institution in the ordinary course of business will disclose information
concerning a consumer's deposit account to third parties.(16) For purposes of
this requirement, the term "third parties" includes other subsidiaries of a
financial institution's parent holding company.(17) In making the required
disclosure, an institution must describe the circumstances under which
information relating to that account generally, not just information concerning
EFTs, will be made available to third parties.(18) The Right to Financial
Privacy Act The purpose of the Financial Privacy Act is to protect consumer
records maintained by financial institutions from improper disclosure to federal
government officials or agencies. Specifically, the Financial Privacy Act
currently prohibits disclosure to the federal government of records held by
certain financial institutions without providing notification to the consumer
whose records are sought(19) and the expiration of a "waiting period," during
which the consumer may challenge and prevent disclosure through legal
action.(20) The Financial Privacy Act requires the government to give the
financial institution a certificate of compliance with the statute before the
financial institution releases customer records.(21) In order to avoid civil
liability for that disclosure, the financial institution must receive and rely
on this certificate in good faith in disclosing the records sought.(22)
Historically, the most significant privacy concern of consumers relates to
government access to their financial records; a concern that far exceeds privacy
questions regarding use of information by bank affiliates or third parties.(23)
The Telephone Consumer Protection Act The TCPA and its implementing
regulation(24) ("TCPA Regulation"), issued by the Federal Communications
Commission, provide consumers with important protections by placing significant
limitations on live telephone solicitations, among other things. Under the TCPA
Regulation, companies can make telemarketing calls to residential telephones
only if: (i) the call occurs between 8 a.m. and 9 p.m. (local time at the called
party's location); (ii) the caller provides certain identifying information to
the consumer; and (iii) the company maintains a company-specific do- not-call
list of persons who do not wish to receive telephone solicitations made by or on
behalf of the company.(25) Thus, if a consumer wishes to opt out of future
telemarketing calls from a particular company, the consumer only need indicate
that he or she does not wish to be called again. The company then must add the
consumer's name to the company's do-not-call list. In other words, the TCPA
Regulation already gives consumers the right under federal law to opt out of
telemarketing calls from a particular company. In addition, the TCPA protects
consumers by, among other things, restricting the use of automatic telephone
dialing devices and prerecorded or artificial telephone messages.(26) Banking
Industry Self-Regulation is Vibrant and Effective The Subcommittee also has
asked me to discuss banking industry self-regulatory efforts to protect consumer
privacy, particularly with respect to electronic commerce. I am pleased to
report today that banking industry self-regulation is vibrant and effective. The
banking industry is far more than just a collection of individual institutions:
each bank has a direct interest in maintaining consumer confidence in the
privacy practices of the industry as a whole. Not only do market forces compel
each individual bank to protect customer privacy, but market forces also give
each bank a direct interest in the adequacy of other institutions' privacy
practices, so that consumer confidence in the banking industry as a whole
remains strong and unwavering. As a result, industry self-regulatory efforts are
extensive and increasing. This determination is underscored by the Federal Trade
Commission's ("FTC") recent report to Congress, entitled Self- Regulation and
Privacy Online, which was released on July 13, 1999.(27) In that report, the FTC
concludes that industry has made significant progress over the past year in its
efforts to self-regulate online privacy and, as a result, that the enactment of
legislation to address online privacy is not appropriate at this time.(28) As
FTC Chairman Robert Pitofsky said in his prepared testimony before a
Subcommittee of the House Commerce Committee, while significant challenges
remain, industry self- regulatory efforts "reflect industry leaders' substantial
effort and commitment to fair information practices. They should be commended
for these efforts."(29) Chairman Pitofsky discussed the rationale for the FTC's
recommendation against new online privacy legislation: " t he Commission
believes that self-regulation is the least intrusive and most efficient means to
ensure fair information practices online, given the rapidly evolving nature of
the Internet and computer technology."(30) While Chairman Pitofsky's statement
was made in the context of online privacy, and did not focus solely on financial
institution privacy-related efforts, the progress to which he refers, and the
efforts that led to that progress, apply equally to the banking industry. The
fact is that, consistent with its long-standing tradition of protecting consumer
privacy, the banking industry has been at the forefront of U.S. industry efforts
to protect consumer privacy in the modern era. One of the best examples of the
banking industry's leadership in efforts to protect consumer privacy, in
electronic commerce and elsewhere, is the early adoption of industry-wide
privacy principles. For instance, in 1995, Visa adopted and published the Visa
Issuer Privacy Principles. In 1996, the ABA and CBA each adopted best practices
guidelines to serve as a blueprint for financial institutions to use in
developing their own policies. Then, in 1997, all the major bank trade
associations jointly adopted uniform Banking Industry Privacy Principles which
have served as the basis for the development of individual privacy policies and
guidelines by financial institutions throughout the country. These financial
institutions, as a result, are obligated, consistent with unfair and deceptive
practices and other standards, to comply with their individual privacy policy
statements. The banking industry also has demonstrated its leadership in
consumer privacy protection through the industry's long-standing, substantial
educational efforts. For instance, ABA, CBA, the Roundtable and Visa have used
their respective Privacy Principles as the basis for privacy training efforts
with thousands of their members around the country. Similarly, among countless
other efforts, ABA provides its members, free of charge, a video training tool
developed by The Chase Manhattan Bank, which is intended to increase both bank
employee and public awareness of privacy issues, such as those relating to
prevention of identity theft and pretext calling; CBA sponsors a number of
efforts to increase awareness of privacy issues among its members, including
weekly programs at which its members discuss key issues with privacy experts;
the Roundtable provides numerous alerts to its members and suggestions in
addressing privacy, and the Roundtable's Banking Industry Technology Secretariat
("BITS") has provided open forums for bankers to attend, be briefed and discuss
privacy issues; and Visa and its member financial institutions have distributed
consumer education programs and materials on a wide range of personal financial
topics extending far beyond privacy to millions of Americans nationwide,
including materials that help consumers learn to live within their means (such
as the Choices and Decisions multi-media teaching curriculum, which assists
consumers in planning their financial futures), help consumers to recognize the
warning signs of potential financial problems, and assist those who are having
trouble get out of debt (like Managing Your Debts: How to Regain Financial
Health, which is distributed by Visa, the Consumer Federation of America and the
National Foundation for Consumer Credit). The ABA, CBA, the Roundtable and Visa
believe that the existing legal framework governing the sharing of information
by financial institutions -- which effectively employs the interplay of consumer
demands, federal laws and regulations, and the teeming marketplace itself --
provides effective consumer privacy protection, while permitting the flow of
information that is vital to the banking industry and to the U.S. economy. The
result? Ready consumer access to, and information about, a universe of products
and services that were only dreamed of just a few years ago. Once again, I want
to thank you for the opportunity to appear before you today on behalf of ABA,
CBA, the Roundtable and Visa. Please let us know if we can be of additional
assistance to the Subcommittee or its staff.
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