HOUSE PASSES EXCEPTION TO GLBA ANNUAL PRIVACY NOTICE REQUIREMENT
The House of Representatives recently passed H.R. 3506, the Eliminate Privacy Notice Confusion Act. The Act would create an exception to the annual privacy notice requirement under the federal Gramm-Leach-Bliley Act (GLBA). The GLBA currently requires financial institutions to provide consumers with an initial and annual privacy notices. Under the Act, a financial institution would not be required to provide an annual privacy notice if the financial institution (i) only shares nonpublic personal information pursuant to an opt-out exception and (ii) has not changed its policies and practices with regard to disclosing nonpublic personal information from the policies and practices that were disclosed in the most recent disclosure to consumers.
If passed by the Senate and signed into law, this legislation would eliminate a significant paperwork burden for debt buyers and other financial institutions under the GLBA who do not share nonpublic personal information outside of its exceptions.
- Michael Tomkies and Charles Gall