Authorities Regarding GLBA Privacy and the FCRA

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One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and the FCRA. Regarding GLBA privacy, we are posting OCC interpretative letters 910 and 917, which remain basic authorities for the interpretation of Section 13. Regarding FCRA, we are posting two letters – “Tatelbaum II” and “Gowen” – which are still key in the interpretation of Section 604(a)(3)(A). Links to all these letters will appear on the Privacy and Data Security Resources page, under the headings Gramm-Leach-Bliley Act and Fair Credit Reporting Act, respectively. Further such authorities will be posted there from time to time.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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