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Customer Confirmation on Receiving Privacy Notice

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Question: 
Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.
Answer: 

Answer by Kathleen Blancard: There is no requirement for acknowledgement of the notice. I would try not to get drawn into such a process. Show how you deliver it with each new customer/account and how you send it each year for the annual notice requirement. There is no requirement for a signed acknowledgement.

Answer: 

Answer by Ken Golliher: Whenever an examiner tells you something that you know to be patently ridiculous (yours is a good example) politely ask for a citation to law or regulation. Their training focuses on their responsibility to provide you with that information if you ask for it.

Regulation P doesn't even have record retention requirements, let alone a requirement for a signed receipt.

First published on BankersOnline.com 8/15/11

First published on 08/15/2011

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