Gramm Leach Bliley Act
Disclosures required by the GLB Act
-Initial Privacy Notice -Opt Out Notices -Annual Privacy Notices
Practices prohibited by the GLB Act
-sharing of account numbers -limitations on the re-disclosure and reuse of information
Who is the regulatory agency of the GLB Act?
CFPB
Annual Privacy Notice
Include notice of the right to opt out and information on exercising the right to opt out -If paper copy requested by telephone must be delivers within 10 days
Opt Out Notice
Must be given if a financial institution plans on sharing NPI with NA3P, gives a consumer 30 days to complete
Initial Privacy Notice
Not required to provide consumers with a privacy notice unless they intend to share the consumer's information with nonaffiliated 3rd parties
What is the purpose of the GLB Act?
To ensure that financial institutions, including mortgage brokers and lenders, protect nonpublic personal information of consumers
Customer
a consumer who has a customer relationship with a financial institution
Consumer
an individual who obtains, from a financial institution, financial products or services which are to be used primarily for personal, family, or household purposes
Affiliate
any company that is controlled by or is under common control with another company
Financial Activities
providing real estate settlement services
Customer Relationship
when a consumer has a continuing relationship with a financial institution
Nonpublic Personal Information
Personally-identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or that is otherwise obtained by the financial institution. Examples include information that a consumer provides to obtain a loan or information from a credit report.
Nonpublic personal information
Personally-identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or that is otherwise obtained by the financial institution. Examples include information that a consumer provides to obtain a loan or information from a credit report.
What is another name for the BLB Act?
Regulation P
Financial Institution
any institution the business of which is engaging in financial activities