ARTICLE
14 December 2018

Federal Register: CFTC Allows Exceptions From Sending Annual Privacy Notices

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 CFTC proposal to amend Rule 160.5 - which requires certain "covered persons" to provide annual privacy notices to customers at least once a year during the life of the customer relationship - was published in the Federal Register.
United States Finance and Banking

The CFTC proposal to amend Rule 160.5 - which requires certain "covered persons" (i.e., FCMs, RFEDs, CTAs, CPOs, IBs, MSPs and SDs) to provide annual privacy notices to customers at least once a year during the life of the customer relationship - was published in the Federal Register. Comments must be submitted by February 8, 2019.

As previously covered, the proposed revisions implement the Fixing America's Surface Transportation Act's (FAST Act) December 2015 statutory amendment to the Gramm-Leach-Bliley Act.

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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