Institutions are required to provide a Privacy Notice to consumers when a new, ongoing customer relationship is established. For most institutions, this notice simply prints out with other required disclosures when a new account or new loan is opened and most don’t give it a second thought. It is important to remember; however, that the Privacy Notice has very specific content and formatting requirements and over time, as the Privacy Notice is updated, those can sometimes fall through the cracks. Using the model form can provide a safe harbor as long as any modifications are explicitly allowed. The instructions to the model form state:
The model form is a standardized form, including page layout, content, format, style, pagination, and shading. Institutions seeking to obtain the safe harbor through use of the model form may modify it only as described in these Instructions.
Kevin explains more in the video.
Published
2025/07/08
