Comment on CFPB-2011-0003-0001

On behalf of Oklahoma Employees Credit Union (OECU) and the 40,000 consumers who are members of the credit union, I am writing to you regarding our concerns related to the Disclosure of Information and Records rule. OECU is primarily concerned with protecting the private information of our account holders. This is a significant issue for consumers in maintaining a relationship with any financial institution. The fewer people and organizations that have access to and the fewer transmissions that take place with such information, the better. Additionally, for so much private information to be centralized with any organization increases the potential impact of a possible data breach. Therefore, while we understand that there are times when it is necessary to share private information, we strongly recommend not involving any third party to do so. In general, OECU feels that we spend too many resources to comply with new or amended rules that result in little benefit to consumers. Instead, these requirements often distract from service training, product development, and other areas that could positively impact our members. Therefore, we recommend that any requirements be simple, specific, and efficient to implement. OECU appreciates the opportunity to comment on these issues. Should you have any questions or concerns, feel free to contact me to discuss.