CFPB Proposes Changes To The Annual Privacy Notice: There Is Still Time To Comment

In December 2011, the Consumer Financial Protection Bureau (CFPB) published a Federal Register (FR) notice [76 FR 75825] on "Streamlining Inherited Regulations."  These regulations consist of federal consumer financial laws that were transferred to CFPB authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act from seven other federal agencies. Among the regulations that were identified as opportunities for "streamlining" was the annual privacy notice required by Regulation P ("Privacy of Consumer Financial Information") issued by the Federal Reserve [12 CFR Part 216].  In its fall 2013 " Statement of Regulatory Priorities," the Bureau continued the process by stating its intent to publish a notice of proposed rulemaking "to explore whether to modify certain requirements under the Gramm-Leach-Bliley Act's implementing Regulation P to which financial institutions provide annual notices regarding their data sharing practices."