Financial Privacy Rule: Interagency Notice Research Project
The FTC, FRB, OCC, FDIC, SEC, NCUA, OTS, and CFTC have completed an interagency notice research project and rulemaking. The goal of the project was to develop, through consumer testing, privacy notices that consumers can understand and use to compare financial institutions’ information collection and sharing practices.
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 along with a prototype financial privacy notice.
On March 21, 2007, the 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 Communication Group.
In March and April 2008, Macro International conducted a quantitative study of approximately 1,000 consumers to test the effectiveness of the proposed model form as compared to three other notice formats. In September 2008, Macro International submitted test data and a research methodology report from the survey. On December 15, 2008, Drs. Alan Levy and Manoj Hastak submitted a report analyzing the survey data. On February 12, 2009, Kleimann Communication Group submitted a validation report recommending a revised opt-out form.
On November 17, 2009, the eight agencies issued a final GLB model form, based on the extensive consumer research and the public comment process. Use of the model form is voluntary. Companies that choose to use the model form will satisfy the GLB disclosure requirements for notices and will obtain a legal safe harbor.
Model Form Online Form Builder
Report by Kleimann Communication Group to FTC and FRB
- “Web-based Financial Privacy Notice, Final Summary Findings Report” [PDF]
- Sample Web form with opt-out
- Sample Web form without opt-out
Final Model Privacy Form under the Gramm-Leach-Bliley Act
- Joint Press Release
- Model Privacy Form, no opt-out [PDF]
- Model Privacy Form, with opt-out [PDF]
- FTC Small Business Compliance Guide [PDF]
Phase 2 Quantitative Research
- Levy-Hastak Report [PDF]
- Macro International Report [PDF]
- Study Data [PDF]
- Study Codebook [PDF]
- Press Release
- Public Comments
Kleimann Validation Report [PDF]
Notice of Proposed Rulemaking
Interagency Proposal for Model Privacy Form under the Gramm-Leach-Bliley Act, Federal Register [Federal Register Format]
Proposed Model Privacy Form [PDF]
- Public Comments:FRB, CFTC, FDIC, FTC, NCUA, OCC, OTS, SEC
Report by Kleimann Communication Group
- "Evolution of a Prototype Financial Privacy Notice"
- Executive Summary of Report by Kleimann Communication Group, "Evolution of a Prototype Financial Privacy Notice
- Joint Press Release
Statement of work for form development work [PDF]
Advance Notice of Proposed Rulemaking
Interagency Proposal to Consider Alternative Forms of Privacy Notices under the Gramm-Leach-Bliley Act, Federal Register [PDF]
January and February 2004 Meetings with Interested Groups and Individuals in Connection with the ANPR
Center for Information Policy Leadership Proctor & Gamble, MBNA, Citigroup, IBM Corporation, Chase, Fidelity Investments [PDF]
National Association of Insurance Commissioners [PDF]
Electronic Privacy Information Center, Privacy Rights Clearinghouse, Consumers Union, and Consumer Federation of America [PDF]