FAST Act Drives Long-Awaited Gramm-Leach-Bliley Amendment

In late 2015, Congress passed the Fixing America's Surface Transportation Act − a vehicle for an amendment to the Gramm-Leach-Bliley Act (GLBA) meant to eliminate the need for certain companies to provide annual privacy disclosures to consumers.

The amendment, which took effect immediately, eliminates the annual notice requirement for financial institutions that:

1. do not share consumer nonpublic personal information with nonaffiliated third parties (with some limited exceptions), and
2. have not changed their policies and practices, with regard to disclosing nonpublic personal information, from the policies and practices disclosed in the most recent annual notice.

This amendment addresses long-held complaints that the GLBA's previous disclosure requirements were unnecessarily onerous and expensive for some businesses. In fact, the December 2015 amendment was just the most recent in a number of actions proposed to mitigate the burden and expense that resulted