Joint Letter to CFPB on Amendments to Privacy Notice Requirement, Gramm-Leach-Bliley Act – Regulation P

RE: Amendment to the Annual Privacy Notice Requirement under the Gramm-Leach-Bliley Act (Regulation P) – Docket No. CFPB-2014-0010/RIN 3170-AA39 

 

Dear Ms. Jackson:

The undersigned trade associations (the American Bankers Association, the Consumer Bankers Association, the Financial Services Roundtable and the Independent Community Bankers of America) are working with our members to comment on the proposal by the Bureau of Consumer Financial Protection (“Bureau”) to amend Regulation P published in today’s Federal Register. The proposal would provide an alternative delivery method for the annual privacy notice required by the Gramm-Leach-Bliley Act, along with several other changes. There is a 30-day deadline to submit comments (June 12). We respectfully request that the Bureau instead provide a 90-daycomment period.

The proposal is an outgrowth of the Bureau’s December 2011 solicitation for regulatory streamlining suggestions. However, the proposal describes an alternative method for delivering privacy notices with numerous conditions and qualifications that have not been previously articulated. For example, in order to take advantage of the alternative delivery method, financial institutions must not only limit their information sharing to one of the established exceptions but must also provide an alternative annual notice, maintain a dedicated webpage, offer customers a toll-free number and institute a number of added compliance steps not previously discussed. Our members need time to evaluate the proposal, discuss the operational ramifications, develop a position and coordinate a response. Thirty days is not enough time for affected entities to complete their analysis and formulate comments on the Bureau’s proposal. 

 

To read the full Comment Letter, please download the PDF.