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Financial Privacy Rule: Interagency Notice Research Project


The FTC, FRB, OCC, FDIC, SEC, NCUA, and OTS are currently engaged in an interagency notice research project to develop, through consumer testing, alternative forms of privacy notices for consumers.

In August 2004, six of the agencies issued a statement of work describing the research design for the first phase, or form development phase, of the project. In September 2004, the agencies selected Kleimann Communication Group to conduct the phase one research. On March 31, 2006, the agencies released the Kleimann report on the form development research.

On March 21, 2007, eight federal GLB agencies jointly issued a notice of proposed rulemaking, pursuant to section 728 of the Financial Services Regulatory Relief Act of 2006, proposing as a model privacy form the prototype notice developed in the phase one research conducted by Kleimann. Commenters have until May 29, 2007, to submit comments on the proposal.

3/21/07
Notice of Proposed Rulemaking [Arial Typefont Format] [Federal Register Format]
Interagency Proposal for Model Privacy Form under the Gramm-Leach-Bliley Act, Federal Register

3/31/06
Report by Kleimann Communication Group, "Evolution of a Prototype Financial Privacy Notice"

12/30/03
Advance Notice of Proposed Rulemaking [PDF]
Interagency Proposal to Consider Alternative Forms of Privacy Notices under the Gramm-Leach-Bliley Act, Federal Register

  • Public Comments
  • January and February 2004
    Meetings with interested groups and individuals in connection with the ANPR
    • 1/20/04
      Center for Information Policy Leadership Proctor & Gamble, MBNA, Citigroup, IBM Corporation, Chase, Fidelity Investments [PDF]

    • 1/26/04
      National Association of Insurance Commissioners [PDF]

    • 1/29/04
      Center for Democracy and Technology, National Consumers League, and Robert Gellman [PDF]
      Larry Ponemon, Ponemon Institute [PDF]
      Mark Hochhauser, Readability Consultant [PDF]

    • 2/4/04
      Independent Community Bankers Association and the America’s Community Bankers [PDF]
      National Association of Attorneys General [PDF]
      Joseph Turow, University of Pennsylvania [PDF]

    • 2/5/04
      Mary Culnan, Bentley College [PDF]
      Peter Swire, Ohio State University [PDF]
      Jim Harper, Privacilla.org [PDF]

    • 2/17/04
      Securities Industry Association [PDF]
      North American Securities Administrators Association [PDF]
      Credit Union National Association [PDF]
      Keystone Expressions, Ltd. [PDF]

    • 2/18/04
      TRUSTe [PDF]
      National Retail Federation [PDF]
      Direct Marketing Association [PDF]
      American Bankers Association, Consumer Bankers Association, Wachovia, Wells Fargo, and Bank of America [PDF]

    • 2/25/04
      Electronic Privacy Information Center, Privacy Rights Clearinghouse, Consumers Union, and Consumer Federation of America [PDF]
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