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#1289333 - 11/18/09 10:42 PM
Re: New model privacy form adopted
RR Joker
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Gold Star
Joined: Nov 2007
Posts: 437
Nevada
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Okay, Mary Beth, you are right TOTALLY CONFUSING TIMELINE--I interpret the below from the FIL to say that to rely on safe harbor, compliance date is 1/1/2011. BUT then it says existing sample clauses will be removed on 1/1/2012 and once clauses removed, to get compliance safe harbor, model forms may be used. So, the very least compliance date won't be until 1/1/2011, correct?
*The Appendix to Part 332 of the FDIC's Rules and Regulations currently contains model language (called sample clauses) that institutions may use in their privacy notices and, if so, they are deemed to be in compliance with the privacy provisions of GLBA. The rule removes, after a transition period, these sample clauses and the associated compliance safe harbor. Thus, financial institutions will not be able to rely on the safe harbor for the sample clauses incorporated into notices that are delivered to consumers on or after January 1, 2011. The sample clauses will be removed entirely from Part 332 on January 1, 2012.
[i]*To obtain a compliance safe harbor after the sample clauses are removed, financial institutions may use the new model privacy notice form.
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#1289352 - 11/18/09 11:18 PM
Re: New model privacy form adopted
Marnie
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Give it a break already, FED. U have screwed up TIL until it not recognizable as a "cost of my credit." It now DICTATES OUR PRODUCT LINES, OVERDRAFTS, ETC. Now we need a "safe harbor" from our own privacy notices. Its just a notice how hard can that be for our little consumer's mind to grasp. GEE!!No end to the madness that is now called the Fed. PC run amuck!!
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WE'RE DOOMED! Our happy little thought for the day!
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#1289461 - 11/19/09 02:10 PM
Re: New model privacy form adopted
ccman
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Georgia Plum
Unregistered
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#1289500 - 11/19/09 02:49 PM
Re: New model privacy form adopted
Mary Beth Guard
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Power Poster
Joined: May 2002
Posts: 6,259
NW IL
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Sorry to rant, but this has me wound up.
My next reaction is "This is your idea of SIMPLIFICATION??"
Plus, I am thinking my printer, which was just purchased in March or so, is not going to last a year at this rate. I thought you were putting these on your Kindle?
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#1289505 - 11/19/09 02:59 PM
Re: New model privacy form adopted
QCL
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Power Poster
Joined: Aug 2002
Posts: 3,094
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The sample clauses we use today are good until the end of 2010. Then if you don't use the new Privacy notice, you lose the safe harbor.
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Opinions are my own and not of my employer.
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#1289522 - 11/19/09 03:17 PM
Re: New model privacy form adopted
ahou
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Power Poster
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
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I think as long as we use the new ones next year for our annual mailing, we'll be compliant by any deadline they have mentioned.
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"Once you learn to read, you will be forever free."
- Frederick Douglass
My Opinion Only.
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#1290028 - 11/19/09 09:40 PM
Re: New model privacy form adopted
Ted Dreyer
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Gold Star
Joined: Jul 2008
Posts: 275
DFW, Texas
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I still am not sure about the 30 days vs 1/1/2011...does it mean we can start using it 30 days after publication but have until 2011 to be in compliance with it?
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I've got a problem for your solution...
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#1290060 - 11/19/09 09:54 PM
Re: New model privacy form adopted
QCL
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New Poster
Joined: Dec 2000
Posts: 90
San Luis Obispo, CA USA
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So which is it 2011 or 2012?
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The opinions expressed here are my own and not those of my employer
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#1290179 - 11/20/09 08:31 AM
Re: New model privacy form adopted
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10K Club
Joined: Jul 2001
Posts: 83,365
Galveston, TX
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"In addition, the Agencies other than the SEC are eliminating the safe harbor permitted for notices based on the Sample Clauses currently contained in the privacy rules if the notice is provided after December 31, 2010."
To perserve your safeharbor, you would have to begin delivering the new model disclosure to all new accounts beginning 01/01/11 and in your 2011 annual mailing. You can begin using the new model disclosure anytime after 30-days from publication.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1290800 - 11/20/09 06:59 PM
Re: New model privacy form adopted
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Gold Star
Joined: Nov 2007
Posts: 437
Nevada
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Georgia, I pulled up the forms but there are not editable.
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#1290809 - 11/20/09 07:02 PM
Re: New model privacy form adopted
Marnie
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10K Club
Joined: Jul 2001
Posts: 83,365
Galveston, TX
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You most likely need more than Adobe Reader - you need the actual Adobe software.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1291344 - 11/23/09 03:13 PM
Re: New model privacy form adopted
brainOverload
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Diamond Poster
Joined: Apr 2001
Posts: 2,245
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I still am not sure about the 30 days vs 1/1/2011...does it mean we can start using it 30 days after publication but have until 2011 to be in compliance with it? After 30 days the regulations with the new form will be effective and it can be used. From that date (which will be sometime in the latter part of December) until December 31, 2010 either the old or the new forms will have the safe harbor for compliance. After January 1, 2011 only the new form will have the safe harbor.
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#1291813 - 11/23/09 08:27 PM
Re: New model privacy form adopted
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New Poster
Joined: Jan 2008
Posts: 9
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is everyone having the same problem, if you click on it to edit the form, it turns blue?
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#1291828 - 11/23/09 08:41 PM
Re: New model privacy form adopted
rlcarey
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New Poster
Joined: Jan 2008
Posts: 9
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how do I get Adobe software?
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#1292094 - 11/24/09 02:20 PM
Re: New model privacy form adopted
rewind411
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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how do I get Adobe software? If youi are going to have the form printed, have your printing company download the form and adapt it. If you must do it in house, there may already be people -- marketing, perhaps? -- that have Adobe Acrobat or a similar PDF editing/creation package. If you need to get Adobe Acrobat for this or another reason, it's available wherever you normally obtain software, or it can be ordered at adobe.com. Be sure you discuss the purchase with your IT staff; you need to be sure your computer can handle it, and IT may not allow you to install it without its intervention.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8
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#1294170 - 11/25/09 09:52 PM
Re: New model privacy form adopted
John Burnett
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100 Club
Joined: Nov 2005
Posts: 101
Nebraska
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Our annual privacy mailing is in March-April so we are going to use the current notices and then work on the new form.
Can't wait to see the "online form builder" that the agencies are going to provide (page 46 of the final rules). ;-)
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#1295537 - 11/30/09 06:28 PM
Re: New model privacy form adopted
Princess Romeo
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Platinum Poster
Joined: Feb 2003
Posts: 875
Big Sky Country
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I thought one of the revisions to the notices was going to be an elimination of the requirement for the annual notice for institutions that do not share outside of the allowed exceptions.
So great, it looks like the "non-sharing" shops are STILL going to have to send an annual notice that essentially says:
"We STILL aren't sharing your information except as necessary to maintain your account and process your transactions and you STILL cannot opt-out but instead of using a small "buck slip" to say this, you're getting a 2 page letter sized form. Don't you feel much better now? Have fun shredding." FWIW, I'm going to recommend to management that we venture outside the safe harbor and continue to send the same old notice we've sent for the past 9 years. We are a non-sharing shop, and I see ZERO benefit to the new form. Honestly, our form has passed muster for 3 exams now, why would it suddenly not be sufficient?!? Watch out world, I'm going rogue!!! 
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#1296221 - 12/01/09 04:32 PM
Re: New model privacy form adopted
RebekahL CRCM
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Platinum Poster
Joined: Sep 2007
Posts: 937
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Ditto! The FED has gone bonkers, again. No end to the madness. No going "green" by the FED.
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#1296460 - 12/01/09 07:04 PM
Re: New model privacy form adopted
ccman
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Georgia Plum
Unregistered
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Maybe the government is going about this the wrong way. They should set up standards for each type
Level 1 -We don't share (except with required core processors).
Level 2 - We only share with affiliates.
Level 3 - We share with anyone and everyone who will pay for it.
Banks would be required to post a sticker on the door saying what level they are.
Government would be required to 'educate' the consumer on what the 3 levels mean.
No opt in/opt out.
Consumer can then pick their bank based on whether they want their information shared or not.
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#1296467 - 12/01/09 07:13 PM
Re: New model privacy form adopted
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10K Club
Joined: Jul 2001
Posts: 83,365
Galveston, TX
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I can hear it now - announcement in the bank lobby:
"Attention customers, the current customer privacy level at this bank is orange. Please do not accept any information from strangers and maintain a close eye on any of your personal information. Any personal information found unattended will be subject to confiscation"
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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