AMENDMENTS TO PRIVACY LAW

The Gramm-Leach-Bliley Act (GLBA) requirement to provide an annual privacy notice has been amended by Title LXXV of the Fixing America’s Surface Transportation Act or the FAST Act of 2015 (Public Law 114-94), enacted on December 4, 2015. The FAST Act amends Section 503 of the GLBA to create an exception to the annual privacy notice requirement for financial institutions that:

  • Do not share nonpublic personal information in any way that requires an opt-in under Regulation P; and
  • Have not changed their policies and practices for disclosing nonpublic personal information from those most recently disclosed.

Proposed rules to amend Regulation P to implement the change are expected from the CFPB in the near future.

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