December 3, 1999
Ambassador David L. Aaron
Undersecretary for International Trade
United States Department of Commerce
14th Street & Constitution
Avenue, NW
Room 350
Washington, D.C. 20230
Re: Revised International Safe Harbor Principles and FAQ's
Dear Ambassador Aaron:
The American Council of Life Insurance ("ACLI") and its roughly 500 member life insurance companies thank you for the opportunity to again comment on the "International Safe Harbor Privacy Principles" and associated Frequently Asked Questions ("FAQ's"). ACLI is a signatory to an insurance industry comment letter and is a member of the Financial Services Industry Coordinating Council, and participated in the drafting of its comment letter. In addition, ACLI is a member of, and endorses, the comments provided by the Coalition of Service Industries.
ACLI's substantive comments are contained in the above-referenced correspondence. We only write here to stress the importance our members attach to a finding that the U.S. financial services industry is adequately regulated with respect to privacy. Our member companies think it essential to reach an understanding that does not require life insurers to go beyond the extensive legal and regulatory requirements that govern our member company privacy practices. As is discussed in other comment letters, the passage of financial services modernization legislation and the issuance of comprehensive regulations regarding the electronic storage and transfer of protected health information by the Secretary of Health and Human Services has significantly altered the privacy landscape for life insurers. We hope that these developments will be considered as your negotiations near completion.
Thank you for the continuing efforts of
the Department of Commerce staff on behalf of U.S. businesses, including
the life insurance industry. Our industry looks forward to working with
you and providing any information you need in connection with this process.
Sincerely,
David Leifer, Counsel
American Council of Life Insurance