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Comment Letters due August 10 for CFPB Proposed Annual Privacy Notification Requirement

The annual privacy notice requirement was lifted by Congress in December 2015, when the issue was included in the Fixing America’s Surface Transportation (FAST) Act. Missouri U.S. Congressman Blaine Luetkemeyer (R-District 3) sponsored the privacy notice legislation, and credit unions strongly supported the effort. The bill took effect upon signing, which means annual privacy notices are no longer required UNLESS there is a change in policy. This will save financial institutions unnecessary compliance costs.

To comply with the FAST Act, the Consumer Financial Protection Bureau (CFPB) has issued a proposed amendment to Regulation P. This regulation requires, among other things, that financial institutions provide an annual notice describing their privacy policies and practices to their customers. The amendment would implement the statutory amendment to the Gramm-Leach-Bliley Act providing an exception to this annual notice requirement for financial institutions that meet certain conditions.

As credit unions strongly supported the privacy notification removal legislation, it would be beneficial to provide comment letters to the CFPB in support of this change. The Heartland Credit Union Association Compliance department is sending a letter in support of this change to the CFPB on behalf of member credit unions and will share the letter with credit unions.

The deadline to send a comment letter from your credit union via PowerComment is August 10.

If you have specific questions about this regulatory advocacy issue, please contact Amy McLard, 314.542.1370.