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On April 15, 2010, eight federal regulators[1] released an "Online Form Builder" that financial institutions can download and use to develop and print customized versions of consumer privacy notices.
The Online Form Builder, based on the model form regulation published in the Federal Register on December 1, 2009, under the Gramm-Leach-Bliley Act, is available in several forms. Different forms are available, depending on whether the institution does or does not provide an opt-out and does or does not permit affiliate marketing.
To obtain a "safe harbor" for the law's disclosure requirements, institutions must follow the instructions in the model form regulation when using the Online Form Builder.
The Online Form Builder is available at www.federalreserve.gov, and each of the agencies will post a link to this site on its website.
[1]These federal regulators are the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Federal Trade Commission, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the Securities and Exchange Commission.
Day Pitney Attorneys Alfred Marks and Michael Lane co-authored an article, "Spokeo, Inc. v. Robins: An Underutilized Defense Against Claims Brought Under Federal Consumer Finance Statutes," for The Banking Law Journal.
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Day Pitney Alert
On February 20, Michael Rave and Michael Dunne spoke at FinXTech R.O.D.E., a conference presented by Autobooks, Bank Director and Microsoft and held at the Advanced Technology Development Center in Atlanta, GA.
On February 20, Michael Rave and Michael Dunne spoke at FinXTech R.O.D.E., a conference presented by Autobooks, Bank Director and Microsoft and held at the Advanced Technology Development Center in Atlanta, GA.
Mike Rave was quoted in an analysis article, "Reg Rollbacks Seen As Bit Player In $28B BB&T-SunTrust Deal," published by Law360.
On December 7, Day Pitney, ICSGroup and CohnReznick co-sponsored "Launching a Private Fund: What You Need to Know."
Jed Davis was quoted in a breaking news article, "New York eases proposed cyber regulations after industry complaints," published by Reuters.
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Eliza Fromberg was quoted in an article, "FINRA's Capital Acquisition Broker Rules Face Tough Sell," in Law360.
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