Federal Regulators Release Model Consumer Privacy Notice Form

Publisher: Day Pitney Alert

April 15, 2010

Day Pitney Author(s) Robert M. Taylor III Michael J. Dunne Richard D. Harris Michael T. Rave

On April 15, 2010, eight federal regulators^[1] released an "Online Form Builder" that financial institutions can download and use to develop and print customized versions of consumer privacy notices.

The Online Form Builder, based on the model form regulation published in the Federal Register on December 1, 2009, under the Gramm-Leach-Bliley Act, is available in several forms. Different forms are available, depending on whether the institution does or does not provide an opt-out and does or does not permit affiliate marketing.

To obtain a "safe harbor" for the law's disclosure requirements, institutions must follow the instructions in the model form regulation when using the Online Form Builder.

The Online Form Builder is available at www.federalreserve.gov, and each of the agencies will post a link to this site on its website.

[1]These federal regulators are the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Federal Trade Commission, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the Securities and Exchange Commission.

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