Federal Model Privacy Form for Regulation 169 Notice
As required by the Financial Services Regulatory Relief Act of 2006 (the "Gramm-Leach-Bliley Act" or "GLBA"), eight federal agencies have adopted a simplified Federal Model Privacy Form ("model form"). The new federal model form (of which there are four versions, from which one version is selected by the licensee based upon the circumstances) was developed for use by federally regulated financial institutions to increase consumers' understanding and ability to make informed decisions regarding the sharing of personal information, as required by the privacy provisions of the GLBA.
Insurance licensees who are subject to Regulation 169 (11 NYCRR Part 420), may choose to use the new federal model forms to satisfy the notice content requirements in 11 NYCRR §§ 420.6, 420.7 and 420.8 of Regulation 169. Insurance licensees should note, however, that wherever the federal forms or instructions refer to "financial institutions," for state insurance regulation purposes, the term should be read as referring to insurance licensees. Insurance licensees are not required to use the new federal model forms to comply with Regulation 169. Insurance licensees may continue to use other types of privacy notices, provided those privacy notices meet the notice content requirements set forth in Regulation 169.