Key takeaways

• On December 4, 2015, President Obama signed into law changes related to the annual privacy policy notice (“Annual Notice”) requirement for financial institutions.
• Under these changes to Title V of the Gramm-Leach-Bliley Act, a financial institution would only be required to provide an Annual Notice if it (1) changes its privacy policies since the last privacy notice provided to its consumers or (2) discloses nonpublic personal information to non-affiliated third parties in a manner that triggers an opt-out right.
• The changes to the Annual Notice requirement seek to ease this regulatory burden on financial institutions—including depository institutions, registered investment companies, U.S. private funds, registered investment advisers and securities broker-dealers—by permitting financial institutions, upon meeting the required conditions, to avoid providing customers with Annual Notices.