The federal bank regulatory agencies, NCUA, SEC, CFTC and FTC jointly released an online utility for generating model privacy notices. The agencies issued a final model privacy notice in November 2009 (as discussed in the November 24, 2009 Alert). The form builder assists entities in creating a model privacy notice by providing a series of amendable PDF documents with the appropriate document determined by the entity’s information sharing practices. Use of the model notice form provides a compliance safe harbor with respect to privacy notices required under the Gramm-Leach-Bliley Act and implementing regulations.
Alert April 20, 2010