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Bureau Updates Regulation P, Implements Legislation Amending GLBA
On Friday, August 10, 2018, the Bureau announced final amendments to implement legislation allowing financial institutions meeting certain requirements to be exempt from sending annual privacy notices to customers.
In December of 2015, Congress amended the Gramm-Leach-Bliley Act (GLBA) as part of the Fixing America’s Surface Transportation Act (FAST Act). The amendment provided financial institutions meeting certain conditions an exemption to the GLBA requirement to deliver an annual privacy notice. A financial institution can use the annual notice exception if it limits its sharing of customer information so that the customer does not have the right to opt out, and has not changed its privacy notice from the one previously delivered to its customer. The rule issued by the Bureau implements this legislation and establishes deadlines for institutions resuming annual privacy notices if their practices change and they therefore cease to qualify for the exemption.