Explanation and Assessment of the Newly Proposed Uniform Privacy Policy

Oct. 2007


The extensive requirements for a privacy policy set out by the Gramm-Leach-Bliley Act
(“GLBA”) continues to spark discussions among federal enforcement agencies to create
one uniform privacy policy to alleviate client confusion. Today’s financial institution
privacy notices are overwhelming and extensive which generally results in clients
ignoring the privacy notice insert. To combat this, on October 13, 2006 Congress
enacted the Financial Regulatory Relief Act (“FRRA”) which requires enforcement
agencies to “jointly develop a model form which may be used at the option of the
financial institution.” In response to the FRRA, the agencies have created a proposed
model form that would be voluntary in use but would provide a safe harbor for those
financial institutions which use it.


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