CFPB Changes Annual Notice Requirement Under Reg. P August 14, 2018 By Michael Young On Friday, the Consumer Financial Protection Bureau announced its “finalized amendments” to Regulation P, an implementing regulation of the federal financial Gramm Leach Bliley Act.
May 01, 2019 · Regulation S-P is the primary SEC rule regarding privacy notices and safeguards. The Risk Alert doesn’t cover all of the requirements of Reg S-P or all of the problems OCIE found regarding Reg S-P over the last two years. The most frequent deficiencies and weaknesses: This memorandum outlines certain changes to the Federal privacy regulations for investment advisers under Regulation S-P that have now taken final effect, including the new model privacy notice (the "Model Form") and related safe harbor adopted by the Securities and Exchange Commission ("SEC"). Investment advisers should review the Model Form and their existing notices under Regulation S-P to Aug 10, 2018 · Additionally, the CFPB removed a provision of Reg P that allows for use of an alternative delivery method, noting that the alternative delivery method created by the bureau will likely no longer be necessary as a result of the annual notice exception. Aug 14, 2018 · The revised Regulation P does not alter existing requirements to provide an initial privacy notice or, in appropriate circumstances, a revised privacy notice. The revised Regulation P additionally permits annual notices to be provided via a “clear and conspicuous” website posting, provided that the customer to whom the notice is provided
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.
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.
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Gramm-Leach-Bliley Act Amendment Eliminates Annual … Both Regulation S-P and Regulation P (together, the “Regulations”) require a financial institution to provide an initial notice to consumers describing its privacy policies and practices, including a description of the circumstances in which the financial institution may disclose nonpublic personal information of a consumer to third parties.