January 5, 2000

Donald S. Clark
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue N.W.
Washington, DC  20580

Advisory Committee on Online Access and Security - Nomination, P004807

Dear Mr. Clark:

I am writing with regard to the Federal Trade Commission's establishment of the Advisory Committee on Online Access and Security.  Bank of America applauds the Commission for taking this step and respectfully submits the nomination of Robin K. Warren to be a member of the Committee.

Ms. Warren serves as the Bank of America Privacy Executive responsible for overseeing our company's customer information policies and practices.  Details of Ms. Warren's experience are included in the attached biography.

Although we recognize that the Federal Trade Commission does not have direct jurisdiction over the banking industry, we believe it is important that the banking industry be represented on the Advisory Committee.  Banks have a long history of maintaining the confidentiality and security of our customers' financial information.  The Federal Trade Commission, through this Advisory Committee and other efforts, will continue to provide guidance and help define standards for online access and security that will affect a variety of financial businesses.  We would appreciate having the opportunity to provide expertise and experience from our industry's perspective as many interests come together to evaluate information security and access in the online world.

We appreciate your consideration of Ms. Warren's nomination to be a member of the Federal Trade Commission Advisory Committee on Online Access and Security.


Kenneth D. Lewis
President and Chief Operating Officer