Forwarded at the request of Joe Hillings:

---------------------- Forwarded by Lora Sullivan/Corp/Enron on 12/06/99 
10:15 AM ---------------------------


"Linda Schmid" <schmid@uscsi.org> on 12/03/99 12:41:00 PM
To: Undisclosed.Recipients@smtp-gw.vma.verio.net
cc:  (bcc: Joe Hillings/Corp/Enron)

Subject: Aaron letter change



Dear Transborder Data Flow Working Group:

A significant change has been made to the letter to Aaron.  The following
two paragraphs have been rewritten to achieve recognition of the adequacy of
the existing federal and state legislative framework.  Under the procedures
of the Directive, the Commission will have to make a determination of
adequacy, thus, the rewrite to soften the suggestion of how they make that
affirmative determination.

Article 25 of the EU Directive calls for "adequate," not "equivalent"
protection, and the Financial Services Modernization Act, added to the
existing federal and state legislative framework, establishes a high and
enforceable standard for notice, choice, access, and security of consumer
information. This comprehensive legislative framework achieves equivalency
to the Data Protection Directive in protecting customer information covered
by Title V of the FCRA.

Over the next 18 months, the European Commission should follow the process
of rulemaking and implementation of the Act during the Safe Harbor
transition, in order to make a subsequent determination of adequacy based on
how the Act is interpreted and applied.  In the short-term the Commission
should conclude that the federal and state financial services regulators,
with their new statutory privacy mandate, can serve as the independent
enforcement bodies for those financial services companies that choose to
certify under the Safe Harbor.

Please let me know if you object to this change.  The comments are due
today.

Sincerely,

Linda Schmid
Director Electronic Commerce
Coalition of Service Industries
805 15th Street NW, Suite 1110
Washington D.C. 20005
Telephone: (202) 289-7460
Fax: (202) 775-1726
Email: schmid@uscsi.org

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 - CSI draft letter to Aaron 11_ 19.doc