Congress Eliminates Annual Privacy Notice Requirement for Certain Financial Institutions

January 28, 2016

President Obama signed into law on December 4, 2015 a bill that amended Section 503 in Title V of the Gramm-Leach-Bliley Act (G-L-B Act), with the result that financial institutions – including investment companies and investment advisers – will be able to forego providing their customers with an annual privacy notice under certain circumstances (Amendment). The Amendment is effective immediately.

This OnPoint explains the conditions that investment companies, investment advisers and other financial institutions must meet in order to take advantage of the Amendment’s exception to the annual privacy notice requirement. This OnPoint also explains that the nature of their businesses and the nature of the nonpublic customer information (NPI) they share with non-affiliated third parties, makes it likely that many funds and investment advisers will be able to meet the conditions set forth in the Amendment, meaning that they may no longer need to provide privacy notices to their shareholders or clients on an annual basis.

Read "Congress Eliminates Annual Privacy Notice Requirement for Certain Financial Institutions."