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Co-author, "Federal Agencies Announce 'Model Privacy Form' Under GLBA," The Metropolitan Corporate Counsel, January 2010

January 1, 2010
Day Pitney Author(s) Robert M. Taylor III

On November 17, 2009, the federal banking agencies and the other federal agencies with jurisdiction over "financial institutions" (the "Agencies") issued amendments to the rules that implement the privacy provisions of the Gramm-Leach-Bliley Act (the "GLB Act"). These amended rules, which are effective on December 31, 2009, announce the adoption by the Agencies of a model privacy form that financial institutions may rely on as a safe harbor to provide disclosures under the GLB Act privacy rules.

The amended rules were issued pursuant to the Financial Services Regulatory Relief Act of 2006 that directed the Agencies to "jointly develop a model form which may be used, at the option of the financial institution, for the provision of disclosures under the GLB Act."

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