posting the annual notice on its web site, if the financial institution meets certain conditions. As of December 4, 2015, section 75001 of the Fixing America’s Surface Transportation Act. 8 (“FAST Act”) amended section 503 of GLBA to establish an exception to the annual privacy notice requirements whereby a financial
Draft privacy notice(s). Create a list of information collection and information sharing practices that must be disclosed to consumers. This list can help you categorize practices per the rule requirements and decide how to structure notices. The privacy rule provides a variety of disclosure options. Privacy of Consumer Financial Information (Regulation P) (a) The model form may be used, at the option of a financial institution, including a group of financial institutions that use a common privacy notice, to meet the content requirements of the privacy notice and opt-out notice set forth in §§ 1016.6 and 1016.7 of this part. Privacy Notices | Are You Disclosing Affiliates Correctly First, Regulation P specifically provides a model notice and instructions for completing the model notice. Both are outlined within the Appendix to Part 1016. When the model notice was first introduced, as with most new or changing regulations, we saw active and concerted efforts to comply with its requirements. Banking Regulations Compliance | Privacy Notice Exemption We were obviously happy to see Regulation P was finally updated, which we passed along to you last week.. As a reminder, you qualify for the exemption to the annual notice requirement if you 1) Are not required to provide a Gramm-Leach-Bliley Act (GLBA) opt-out; and, 2) You have not changed your Regulation P sharing practices since your last notice was provided.
12 CFR Appendix to Part 1016 - Model Privacy Form | CFR
Aug 13, 2018 · BCFP finalizes privacy notice regulatory relief August 13, 2018 The Bureau of Consumer Financial Protection Friday issued a final rule amending Regulation P, providing regulatory relief by exempting credit unions that meet specific criteria from the requirement to send annual privacy notices to members. 13. To what extent do financial institutions use the model privacy notice and if not, would they choose to do so to take advantage of the proposed alternative delivery method? 14. Comments are also being sought on the benefit to consumers of receiving the model privacy notice rather than a privacy notice in a non-standard format. 15.
If you use a short-form initial notice for non-customers according to § 1016.6(d) of this part, you may deliver your privacy notice according to § 1016.6(d)(3). [Codified to 12 C.F.R. § 1016.4] § 1016.5 Annual privacy notice to customers required. (a)(1) General rule.