July 7, 2010
While in principal I have no real objection with this proposed rule change, I believe that it is unnecessary in the case of hard data transfers via hard devices such as memory sticks, DVD, CD-Rom, etc. Encryption while delivering data via the internet would be understandable but not for this type of media.
I submit that delivery via this type of media is no different than the delivery of any hard copy data other than convenience. If the submission were to be hard paper copies of records then the data would be just as visible and usable as a DVD or other electronic storage device, and arguably not as secure as the DVD, or memory stick as at least some follow up steps would be needed to view beyond the discovery or theft of the documents. As such I view this rule change as either not broad enough to cover ALL types of hard data transfer (including actual copies) or it is inconsistent and therefore simply adding an unnecessary layer of cost and inconvenience to the normal process of business.
If the rule change required all submission to be via electronic media, AND that the all the data be encrypted, it would make more sense. Dropping a hard copy in the mail requires no encryption, why does dropping a disk containing the exact same information require encryption? As it stands it is just a rules to make rules which is a waste of everyone's time.
Chief Executive Officer
Regal Financial Group
2687 44th. St. SE
Kentwood, MI 49512