BOARD OF GOVERNORS
DIVISION OF CONSUMER
July 5, 2011
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS
SUBJECT: Revised Interagency Examination Procedures for Regulation P
The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently approved the attached interagency examination procedures for Regulation P - Privacy of Consumer Financial Information. Regulation P prohibits a financial institution from disclosing nonpublic personal information about consumers to nonaffiliated third parties, unless it satisfies various notice and opt-out requirements. Regulation P also requires a financial institution to provide notice of its privacy policies and practices to its customers. These revised procedures supersede the Regulation P interagency examination procedures transmitted with CA 01-5.
Specifically, this CA letter transmits examination procedures that reflect a Regulation P interagency rulemaking through which the Federal Reserve and seven other federal regulatory agencies adopted a voluntary model privacy notice form designed to make it easier for consumers to understand how financial institutions collect and share nonpublic personal information. A financial institution can use the model form to obtain a "safe harbor" for compliance with the requirements to notify consumers of its information-sharing practices and their right to opt out of certain sharing practices.
If you have any questions, please contact Amal Patel, Supervisory Consumer Financial Services Analyst, (202) 912-7879, or Paul Robin, Manager, Oversight and Policy, at (202) 452-3140.