Privacy and GLBA - Model Forms


On January 12, 2011, the Office of Thrift Supervision (OTS) published information intended to help small thrifts comply with the obligation to send initial and annual privacy notices to their customers. The agency’s "Small Entity Compliance Guide for the Model Privacy Notice" is aimed at helping small thrifts use the model privacy notice form established by the bank and thrift regulatory agencies in December 2009. Proper use of the model forms provides a safe harbor for compliance with the privacy notice duties.

On December 1, 2009, the agencies published the final rule relating to the model privacy notice. Financial institutions that elect to use the model privacy form may rely on the model privacy form as a safe harbor to comply with the GLBA disclosure requirements.

The effective date of the amendments was December 31, 2009, except for the amendments eliminating the sample clauses and associated guidance, which become effective for notices sent after December 31, 2010.

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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.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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