On October 20, 2014, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule to allow companies that limit their consumer data-sharing and meet other requirements to post annual privacy notices online instead of distributing individual paper copies annually. The new rule applies to both banks and non-banks within the CFPB’s jurisdiction as outlined in the Gramm-Leach-Bliley Act. Under the new rule, institutions that meet certain conditions will be allowed to include the notices on regular consumer communication, such as a monthly billing statement for a credit card, alerting customers that the annual privacy notice is available online and in paper by request at a provided telephone number. Institutions that choose to rely on this new method of delivering privacy notices will be required to use the model disclosure form developed by federal regulatory agencies in 2009.
The CFPB final rule is available at: