Federal Agencies Release Model Privacy Notice
Eight federal regulators, including the SEC, released the final model privacy notice for use by entities, including investment companies, advisers and broker-dealers, subject to the Gramm-Leach-Bliley Act. The agencies provided two forms: one that includes an opt-out and one that does not. The accompanying 260-page release indicates that using the model form provides users a safe harbor to satisfy the disclosure requirements for privacy notices.
OUR TAKE: We can’t really envision why firms would not use the model notice given its safe harbor. We expect the look of the model privacy notice will become as ubiquitous (and unread) as credit card interest rate disclosure statements.