Earlier this month, the Consumer Financial Protection Bureau (CFPB) posted its semi-annual update of its rulemaking agenda for the coming 12-month regulatory cycle, including recently-completed rulemakings.  The rulemaking agenda is part of a broader initiative led by the Office of Management and Budget (OMB) to publish a Unified Agenda of federal regulatory and deregulatory actions across the federal government.  The agenda lists potential changes to the annual privacy notice requirements in Regulation P, which implements the Gramm-Leach-Bliley Act privacy provisions, as being in the “prerule stage.” 

In December 2011, the CFPB solicited public comments on streamlining the regulations transferred to it as part of the Dodd-Frank Act.  The CFPB received comments pertaining to Regulation P suggesting that elimination of the requirement to provide annual notices where there has been no change in underlying policies would reduce unnecessary regulatory burden and unwanted paperwork for consumers at least where a financial institution limits the sharing of information with third-parties.  After reviewing policy options, the CFPB expects to begin developing a proposed rule to seek comment on revisions to Regulation P around November 2013. 

The CFPB’s announcement follows the House of Representatives’ passage of legislation that would eliminate the annual GLBA privacy notice requirement, covered here.