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With the recent transfer of authority for many consumer financial regulations to the Consumer Financial Protection Bureau (CFPB), now may be a good time for a refresher on one of those regulations…Regulation P.
Regulation P requires financial institutions to provide particular notices concerning the disclosure of nonpublic personal information. On December 1, 2009, numerous regulatory agencies jointly released a voluntary model privacy notice that provided regulatory safe harbor to institutions that began using it on or before December 31, 2010. The multiple agencies’ regulations were replaced (with no substantive changes) by the CFPB’s Regulation P on January 1, 2012.
The purpose of the model form is to provide your credit union with a safe harbor from non-compliance. But, keep in mind that simply using the model form does not provide you with the safe harbor…you must also follow the instructions that come along with the form, exactly as they are written. There are very few instances where you are allowed to deviate from the written instructions.
Here is a link to the model form and instructions: Appendix A to Part 1016.
The instructions are long, but are relatively simple to follow. Just be sure to go through the form step by step as you read the instructions. Based on what I have seen in the field, it will take you some time on the front end, but will save you considerable time and expense on the back end (as long as you fill-out the notice correctly the first time).
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