Privacy: Annual Notice Requirements

The Privacy rules have been around for twenty-plus years or so, and for a good part of that time, there weren’t really any major changes. You probably recall that the model form did change along the way and in the last five years or so there were some changes with respect to providing the annual notice. Most of the annual notice changes are beneficial to the financial institution, which does not happen in compliance very often. From time to time, we still see financial institutions that aren’t aware of these changes.

Kevin explains more in the video.


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Video Highlights:

  • Financial institutions are required to provide an annual notice of their privacy policies to consumer customers.
  • An annual notice is not required if the financial institution has not changed its policies and does not provide an opt-out.
  • Posting the notice on the bank’s website is no longer necessary for meeting this exception.

Published
2023/06/13

 

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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