Do we have to use the model privacy notice or can we use our own?

You can use your own, but starting Jan, 2011 you lose your safe harbor for use of the old sample clauses.

That menas if i have yearly mailing due to send out in August, i can use the current one. Next Year mailings i would have to use the New model form that looks like a food contents chart right.

The way I understood it was you can mail your current one in your August mailing but would then need to mail the new form in January so it would only make sense to mail the new one in August and you wouldn't have to mail again until next August.

Can i take the contents of my existing one and plug it in to the model one provided by the Fed?

Can anyone direct me to where I can find the support for having to mail a new notice Jan 1, 2011 as opposed to waiting to send the new notice at the time of our annual mailing in '11 if we mail our old notice in 2010? I'm trying to determine if just a notice of policy change would need to be mailed in Jan 2011 or if the new full blown notice would have to be mailed. Thanks.

My interpretation was that safe harbor on the existing model expires at EOY 2010. Beginning with the 2011 mailings, the new model will need to be used to receive safe harbor. Therefore, my current plan is to continue using the 'old' disclosures for new customers as well as our annual mailing in October to existing customers, then beginning on 1/1/2011 for NEW customers use the 'new' model form privacy disclosure as well as for our annual mailing in October 2011.
Our privacy policy won't change, just the format to comply with the new model.