Gramm-Leach Bliley Act

Initial Privacy Notice

Describes the financial institution's practice of sharing non public information with affiliates and third parties and the types of information shared Due at the time the customer relationship is estabblished .

Purpose

Ensure that financial institution's protect nonpublic personal information • Regulation P

The Safequards Rule

Ensures protection of privacy of personal information with the implementation of an effective security program.

Disclosures

If a financial institution plans to share consumer/customer nonpublic information with a third party, they must provide an Initial Privacy Notice and an Opt-Out Notice

Non Public-Personal Information

Information provided by consumer to obtain financial products Account information History of relationship with institution • Information obtained from internet "cookie" • Information from credit reports • SS#

Opt-Out Notices

Informs customers of their right to opt-out of the sharing of information. Customer has 30 days to complete an opt-out form. Starts from date on which the notice was mailed. Will be resent annually.

Check point: if a financial institution plans to share their customer's nonpublic information with a third party, they must provide an and

Initial Privacy Notice Opt-Out Notice

annual privacy notice

will be sent out as well, contains same information as the Initial Privacy Notice

Customer Relationship

• A customer relationship is established when a consumer has a continuing relationship with a financial institution. Enter an agreement from consumer to obtain a loan Enter an agreement to obtain a mortgage Have an agreement to have loan serviced

Check point : Customers have days to complete an opt-out notice.

30 days

The Safeguards Rule Requires:

: A company overseer to coordinate program Identifying risks to the security of customer information Regular testing of the security program Oversight of service providers who have access to customer information

Check Point True or False, the Initial privacy notice is due at time customer relationship is established

Answer: True

Public Information

Anything recorded at a court house Telephone numbers • Websites, Social Media, Etc.

Consumers

Consumers-individual who conduct isolated transactions with financial institutions Using an ATM Cashing a Check • Wire Transfer