Federal Regulators Propose Model Privacy Forms Under the Gramm-Leach-Bliley Act
By The Investment Management Practice Group
Eight federal regulators have issued an interagency proposal for a new model privacy form that financial institutions (including registered investment advisers, registered investments companies and registered broker-dealers) can use for their privacy notices to consumers, as required under the Gramm-Leach-Bliley Act (the GLBA). Under the GLBA, financial institutions must provide individual customers with a notice that describes, among other things, the institutions consumer information sharing policies and practices and the consumers right to direct the financial institution not to share certain information. Presently, the GLBA and current rules do not mandate a standard form of notice or particular wording for a notice, although they do provide sample clauses that financial institutions can use to satisfy the notice requirement.