Online Form Builder for Consumer Privacy Notices
Posted May 18, 2010 by Bierce & Kenerson, P.C. · 
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The privacy of consumer financial transactions was a cornerstone of the Gramm-Leach-Bliley Act (GLB). Eight U.S. federal regulators are responsible for enforcing the GLB privacy rule: the Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Federal Trade Commission, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision and the Securities and Exchange Commission (SEC).
In light of the importance of privacy, financial institutions have sought and finally obtained some predictability in their compliance.
Model Form of GLB Privacy Notice. On November 17, 2009, the eight agencies issued a final GLB model form that, if used, provides a legal safe harbor to firms that voluntarily choose to use the model form in satisfaction of the GLB disclosure requirements for privacy notices.
Online Form of GLB Privacy Notice. On April 15, 2010, the eight federal regulators released an Online Form Builder that regulated financial institutions can download and use to develop and print customized versions of a model consumer privacy notice. The “form builder’ enables a regulated financial institution to select the version of the model form that fits its practices, such as whether the institution provides an opt-out for consumers.
To obtain a legal “safe harbor” for complying with the law’s disclosure requirements, financial institutions must follow the instructions in the model form regulation when using the Online Form Builder. The Online Form Builder is available at: http://www.federalreserve.gov/newsevents/press/bcreg/privacy_notice_instructions.pdf
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Filed under: Newsletter Article
Tagged: Consumer Privacy, federal reserve, GLB Privacy Notice, Online Form Builder, Safe Harbor