QuestionQ159

Federal Privacy Laws

Under GLBA, which of the following organizations would not have to give its customers an annual privacy notice?

  • A An insurance company that has no privacy department.
  • B An auction house that also acts as a financial institution.
  • C A credit union that has made changes to its privacy notice from last year.
  • D A credit union that has not made changes to its privacy notice from last year.
Explanation

GLBA’s annual privacy-notice exception applies to a financial institution that limits disclosures of customers’ nonpublic personal information to disclosures that do not trigger an opt-out right and that has not changed its information-disclosure policies and practices from those stated in its most recent privacy notice. A credit union with no changes to its privacy notice satisfies the stated no-change condition for that exception, assuming its disclosures also meet the limited-sharing condition.

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