Model Privacy Form Under the Gramm-Leach-Bliley Act

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Interagency Proposed Rule for Model Privacy Form under the Gramm-Leach-Bliley Act (GLB Act). The proposal responds to Congress’s direction in the Financial Services Regulatory Relief Act of 2006 for multiple federal agencies to jointly develop a model form that may be used at the option of financial institutions to provide initial and annual privacy notices under Section 503 of the GLB Act.  SIFMA believes the model form is overly simplistic in some sections, and offers its observations and recommendations to the SEC.  SIFMA is sending copies of its recommendations to the other agencies involved in the proposal: the Federal Trade Commission, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, the Commodity Futures Trading Commission, and the National Credit Union Administration.