On May 6, 2014, the Consumer Financial Protection Bureau (“CFPB”) proposed a rule to modify the notice provisions of Regulation P, which implements the financial privacy provisions of the Gramm-Leach-Bliley Act (“GLBA”).

Regulation P requires financial institutions to deliver an annual privacy notice to customers, which is often accomplished through a direct mailing to the customer.  The proposed rule would allow a financial institution to meet this annual privacy notice delivery requirement, in certain circumstances, by continuously posting the privacy notice on its website in a clear and conspicuous manner (described as the “proposed alternative delivery method” in the proposed rule), and providing the customer with a clear and conspicuous annual disclosure that (i) the privacy notice has not changed, (ii) the notice is available on the institution’s website, and (iii) the customer may request a mailed copy of the notice by calling a toll-free number.…

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