CFPB's Promise To Ease Privacy Notice Burdens Needs Clarification

The CFPB has proposed allowing financial institutions to forgo mailing annual privacy notices by posting such notices online, if the financial institution meets certain conditions. While the proposal is welcome, it needs clarification to ensure that it actually provides the intended relief of easing the burden imposed by the annual privacy notice requirement under the Gramm-Leach-Bliley Act.

Introduction

Financial institutions currently mail a separate privacy notice every year to each customer. The proposed amendment to the GLBA Privacy Rule would allow institutions that meet certain requirements, such as using the CFPB's Model Privacy Notice, to post the privacy notice online and include a reminder of the notice's availability in regular mailings to consumers once per year.