| MoFo Reenforcement

The CFPB Catches Up to the FAST Act: Implements GLBA Annual Notice Exception

By Nate Taylor, Jeremy Mandell and Elyse Moyer on August 28th, 2018 Posted in CFPB, Privacy, Regulatory Developments

On August 17, 2018, the Bureau of Consumer Financial Protection published a final rule amending its Regulation P to include an exception to the Gramm-Leach-Bliley Act annual privacy notice obligation. Nearly three years ago, the Fixing America’s Surface Transportation Act (FAST Act) amended the GLBA to provide for such an exception. The CFPB has now… Read More

#ThrowbackThursday: Federal Agencies Issue Model GLBA Privacy Form

By MoFoReEnforcement on February 4th, 2016 Posted in Privacy

In December 2009, Morrison & Foerster published the client alert “Federal Agencies Issue Model GLBA Privacy Form.” The federal banking agencies and the CFTC, FTC, NCUA and SEC (“Agencies”) have issued a final rule amending their privacy rules under Title V of the Gramm-Leach-Bliley Act (“GLBA”). The purpose of the amendments is to provide a… Read More

CFPB Issues Final Privacy Notice Rule

By Amanda Mollo on November 4th, 2014 Posted in CFPB, Privacy

On October 28, 2014, the Consumer Financial Protection Bureau (CFPB) published a final rule in the Federal Register amending the annual privacy notice requirement under the Gramm-Leach-Bliley Act and Regulation P. The GLBA and Regulation P require financial institutions to provide an initial privacy notice to consumers when they establish a customer relationship with the… Read More