Finally!! On August 10th, the CFPB announced it had finalized amendments to Regulation P. And to think it only took a little under three years to get it done!
Back in December 2015, we alerted you that President Obama signed the FAST Act into law, which effectively eliminated the annual privacy notice requirement for banks whose sharing practices:
- Do not require an opt-out under the Gramm-Leach-Bliley Act; and,
- Have not changed since the last time they sent their Privacy Notice.
Our advice to banks at the time was that the law is the law and they could begin to follow the FAST Act rules right away. Many have and to our knowledge did not experience any difficulties with their examiners. Others were a little hesitant to follow the law until a regulation was finalized. Thankfully, the wait is over.