Developments of Note
Federal Banking Agencies and FTC Release Answers to Frequently Asked Questions on Gramm-Leach-Bliley Privacy Issues
The FRB, OCC, FDIC, OTS, NCUA and FTC released virtually identical "Frequently Asked Questions for the Privacy Regulation" (the "FAQ"), a collection of questions and answers on a variety of issues related to the Gramm-Leach-Bliley Act privacy regulations that they prepared in consultation with the SEC and CFTC. The FAQ does not clarify the fundamental question of what institutions are financial institutions subject to the privacy regulations. The FAQ does, however, commit the agencies to a number of significant clarifications of various other aspects of the privacy regulations, including: