[rcooper]

A question we received:

We have heard we no longer have to send privacy notices. We only have to give the notices with new accounts. Our bank is not required to offer the opt-out option (we do not share information). We thought we had to list the model language on account statements and put a copy of the privacy notice on our web site. We also thought we had to mail the notice annually to customer that didn’t not receive the model language on their statements (like loans, CD’s, Safe Deposit boxes, etc.). What is your opinion?

Answer: You don’t have to send the annual privacy notice if you don’t share information requiring an opt-out and you haven’t changed your policy. If your bank changes its disclosure practices/changes its policy and shares NPPI that requires an opt-out you would need to send a new privacy notice.

Here’s an article Jack posted to the blog in December of last year addressing the amendment: https://mycomplianceresource.com/amendments-to-privacy-law/

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