ARTICLE
20 August 2018

CFPB Exempts Certain Financial Companies From Privacy Notice Requirements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Consumer Financial Protection Bureau ("CFPB") adopted a final amendment that will exempt certain financial institutions from the requirement of providing privacy disclosures ...
United States Privacy

The Consumer Financial Protection Bureau ("CFPB") adopted a final amendment that will exempt certain financial institutions from the requirement of providing privacy disclosures under Regulation P (Privacy of Consumer Financial Information).

Regulation P generally requires financial institutions to provide customers with an annual notice describing its privacy policies and procedures. The amendment will exempt from this requirement institutions that (i) do not share any nonpublic personal information about customers and (ii) have not changed their disclosure policies since the most recent privacy notice was sent to their customers. The CFPB is also making several corresponding technical revisions to Regulation P. The amendment was adopted in accordance with changes to the Gramm-Leach-Bliley Act.

The amendment will become effective 30 days after its publication in the Federal Register.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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