Removing Barriers Blog

Comment Call for Proposed Changes to GLB Privacy Notification Rule
Posted July 12, 2016 by CUNA Advocacy

This week the CFPB proposed changes in the Federal Register stemming from the Fixing America’s Surface Transportation (FAST) Act, which was passed into law last year amending the Gramm-Leach-Bliley Act (GLBA). We strongly supported and advocated for the passage of this legislation, which modernizes requirements for providing information about privacy notices. The annual privacy notice has been an unnecessary compliance cost for many years.  

We were extremely pleased to finally see changes made to this requirement. Changes were first made allowing an alternative delivery method (website) rule in 2014 followed by the FAST Act, which eliminated the general annual notice requirement in December 2015.  

Accordingly, this month CFPB, as required by the FAST Act, put out a proposed rule amending Regulation P under the GLBA to provide that a financial institution is not required to deliver a GLBA annual privacy notice if it uses an alternative delivery method. 

Under the proposed rule, credit unions that meets the criteria for this alternative delivery method would also meet the requirements for the new annual notice exception. 

The proposal is out for comment until August 10, 2016. We will be filing a comment letter, and credit unions are encouraged to review our comment call.