ABA has issued a staff analysis of the CFPB’s proposal to ease the annual privacy notice requirement under the Gramm-Leach-Bliley Act. Under the proposed rule, banks may post their privacy notices online rather than delivering them individually in certain circumstances.
The analysis outlines the five conditions under which a bank may forego mailing an annual privacy notice, as well as the three requirements the CFPB proposed for banks that use the alternative delivery method.
ABA invites bankers to share input on their current privacy notice practices and the prospects for adjusting those practices to make the proposed alternative annual notice process feasible.
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