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All in Privacy
In this Compliance Clip (video), Adam answers a question as to whether an annual notice is required to be provided on each periodic statement. This clip provides a great overview of the history of the privacy annual notice exemption and even the current exemption rules.
As the current privacy policy model form used as the safe harbor under Regulation P has been around for nearly a decade now, it is easy to just assume that all the kinks with the implementation of that model form have been worked out and your privacy policy is in compliance. While this is the case the majority of times, sometimes certain things get lost over time.
This Compliance Clip (video) discusses the August 2018 amendments to Regulation P. This final rule does four things and Adam provides a summary of the changes, including the exemption to sending the annual privacy notice from qualifying institutions. Those institutions who provide a privacy notice only because of the FCRA opt-out should pay particular attention to this video, as the new amendments provide relief to certain institutions. The video also discusses the timing requirements for institutions who lose their exemption due to a change in their privacy policy. In a rare "reference moment," Adam ends this video with one of his favorite quotes from "The Truman Show."
Over two and a half years after the privacy laws were amended by Congress, the CFPB has finalized the revisions to Regulation P. This final rule affects financial institutions that do not share nonpublic information to third parties, though financial institutions who do share information will see little changes to their existing practices. The final rule was released on August 10, 2018 and will become effective 30 days after publication in the Federal Register.
This executive summary provides an overview of the changes which can be shared with management.
