Feds Release Usable Model Consumer Privacy Notice

There was much cheering when federal regulators finally released their Final Model Privacy Notice Form back in November.

That was quickly followed by a gnashing of teeth when it turns out the regulators did not understand the concept of a form or how to use Adobe Acrobat. They merely created a static document that you would have to spend hours trying to recreate.

They finally released version of the model privacy notice that is a fillable form using adobe acrobat.

To obtain a legal “safe harbor” and so satisfy the Gramm-Leach-Bliley Act’s disclosure requirements, institutions must follow the instructions in the model form regulation when using the Online Form Builder.

Sources:

Federal Regulators Issue Final Model Privacy Notice Form

Eight federal regulatory agencies today released the final model privacy notice form. It’s supposed to make it easier for consumers to understand how financial institutions collect and share information about consumers. Under the Gramm-Leach-Bliley Act, institutions must notify consumers of their information-sharing practices and inform consumers of their right to opt out of certain sharing practices. The two model form issued today can be used by financial institutions to comply with these requirements. One form allows consumers to opt out of sharing of personal information. The other form has no opt-out.

Back in April, the Securities and Exchange Commission reopened the period for public comment because they tested the model notices and found weaknesses with the current form.

The final model privacy form was developed jointly by the Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Federal Trade Commission, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, and Securities and Exchange Commission. There is also a joint release of the rule that goes along with the Final Model Privacy Form under the Gramm-Leach-Bliley Act

References:

More than 100 Banks Have Failed in 2009

FDICBank closures are usually symptomatic of the economy. Last Thursday, the number of banks subject to FDIC closure stood at 99. Since FDIC take-overs are usually Friday afternoon, the question was “Would the FDIC would reach one hundred this weekend?”

They smashed through the century mark, closing seven banks over the weekend:

This rate of closure is bad, but not the worst.

The most failures occurred in 1989 when 534 banks and savings and loans were closed, which is an average of more than 10 per week. Although there were twice as many insured institutions in 1989: 16,574 in 1898 versus about 8,200 today.

The last time more than 100 FDIC-insured institutions were closed was in 1992, when 181 failed. The first time more than 100 FDIC-insured institutions failed in a year was 1982, when 119 were closed. From 1984 through 1992, more than 100 institutions were closed each year.

This is a lit more interesting when you look at it visually: (from Calculated Risk)

FDICFailures

References: