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The model privacy form is designed to make it easier for consumers to understand how financial institutions collect and share their personal financial information and to compare different institutions’ information practices. Monitor NCUA and CFPB announcements for any future amendments or interpretive guidance to Regulation P. If you prefer to continue delivering annual privacy notices to your customers by the other existing methods contained in Regulation P, you do not need to take any action. Existing methods include hand-delivering or mailing a printed notice. In December, President Barack Obama signed into law the Fixing America’s Surface Transportation Act. Buried on page 476 of this 490-page bill is an amendment to the consumer privacy provisions of the Gramm-Leach-Bliley Act (the GLBA) that eliminates the annual privacy notice requirement for certain financial institutions, as further described below. The FRB last week allowed FRB banks to no longer send an annual privacy Notice if nothing has changed. This is reportedly an interagency exam revision but it is not in the OCC or FDIC data and it only addresses Reg P which the FDIC does not follow.
The privacy notices under the GLBA/Regulation P and affiliate disclosures under the FCRA/Regulation V interact in two ways. First, section 603(d)(2)(A)(iii) of the FCRA excludes from that statute's definition of a consumer report [ 20 ] the sharing of certain information about a consumer with the institution's affiliates if the consumer is