Trade Associations Submit Comment Letter Regarding CFPB Privacy Notices

SIFMA, the American Bankers Association, the Consumer Bankers Association, the Financial Services Roundtable and the Independent Community Bankers of America (the "Associations") submitted a joint comment letter to the CFPB regarding its proposal to amend Regulation P.

Regulation P implements the consumer privacy provisions of the Gramm-Leach-Bliley Act ("GLBA"), which requires financial institutions to provide an annual disclosure of their privacy policies to their customers. In the letter, the Associations stated that the changes proposed by the CFPB are in the right direction but are also insufficient.

The Associations strongly urged the CFPB to eliminate the annual notice as superfluous where there is no sharing under either GLBA or the Fair Credit Reporting Act that would require the institution to offer customers an opt-out. The letter asserts that there should be alternative and more efficient methods for communicating customer privacy and opt-out rights that would prove less costly than the current "regime of annual notice."

See: Comment Letter; Consumer Privacy Notices.