CFPB Finalizes Changes to Annual Privacy Notice Requirements

The Consumer Financial Protection Bureau (CFPB) has issued its final rule adopting changes to Regulation P, which governs the requirements for financial institutions to issue privacy notices to its customers. The final rule implements new timing requirements for sending annual privacy notices pertaining to financial institutions who no longer qualify for the exception and eliminates the “alternative delivery” option for annual privacy notices. The most significant impact of the final rule is the creation of an exception which permits financial institutions to avoid sending annual privacy notices to its customers under certain circumstances.

The final rule will have the biggest impact on financial institutions who do not share nonpublic personal information with unaffiliated third parties. However, with recent amendments to the Gramm Leach Bliley Act (GLBA) and Regulation P regarding privacy notices, all financial institutions should evaluate their current privacy policies and procedures. The final rule will become effective on September 17, 2018.

Read Baker Donelson’s full analysis of the upcoming changes here.

Alexander F. Koskey, CIPP/US

Associate at Baker Donelson
Alexander F. Koskey, CIPP/US is an associate in Baker Donelson's Atlanta office. Contact him at

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