May 13, 2014
BY AMANDA KOWALSKI & LAWRENCE D. KAPLAN
The Consumer Financial Protection Bureau (“CFPB”) recently proposed a rule (the “Proposed Rule”) allowing companies that do not share customer information with third parties to post their annual privacy notices online, rather than physically or electronically delivering them, in order to promote more effective privacy disclosures from financial institutions to their customers. Permitting electronic posting of privacy notices in this limited circumstance is intended to reduce information overload for consumers, while allowing financial institutions to reduce their compliance expenses.
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