I am having a disagreement with a co-worker about our privacy notice. Is it REQUIRED to be on our website? We are a small bank so customers can't open anything on line. We share with no one so our privacy notice is the basic. I'm lean towards putting it out there and side on caution, co-worker says not necessary but if it would be me feel better. GRRRRR. I just want to know is it required?

https://www.federalregister.gov/articles...ct-regulation-p

Section I (Summary of the Rule) Paragraph 2. Yes, it is required to be on your website.

Putting it on the website is not required, but is an option for certain situations.

1. The only time privacy notices are required any more is at account opening. An annual notice is no longer required as long as you meet the criteria defined in the recently passed FAST Act. Here is a thread about it https://www.bankersonline.com/forum/ubbt...ted#Post2052740

2. If you do not meet the criteria and are still required to have an annual notice, then putting it on the website is one option of doing that. But, you must also put in customers statements a message letting them know that it is available on the website.

3. If you are required to send an annual notice you can still send it out by mail and not do the alternative method of putting it on the website.

No, it is not required. The issue has evolved. See page 10 of the current Interagency Examination Procedures for Regulation P.

Thank you.