The federal financial services agencies are expected to shortly announce a proposed-final Gramm-Leach-Bliley Act (“GLBA”) model form privacy notice. The model notice incorporates financial institutions’ required disclosures pursuant to Section 503 of the GLBA. Financial institutions that use the form to provide notice to consumers will be deemed in compliance with the privacy notice provisions of the GLBA. Once adopted and published in the Federal Register, the financial services agencies’ final model notice will take effect in 30 days.
The GLBA requires, in relevant part, that financial institutions provide consumers with notice of their privacy policies and practices. The privacy notice must describe a financial institution’s disclosure of nonpublic personal information to affiliated and nonaffiliated third parties. In addition, the notice must also give consumers a reasonable opportunity to opt out of certain sharing with nonaffiliated third parties.