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Compliance Companion®
Standard Procedures Manuals (SPM)
 

Financial Privacy & Information Security October 2017


This Manual summarizes the principal laws and regulations governing the privacy of consumer financial information from the perspective of a financial institution. Part One provides an introduction to the topic and explains how the Manual is organized. Part Two includes a detailed discussion of the privacy rules under the Gramm-Leach-Bliley Act (GLBA) and Regulation P, followed in Part Three by the privacy and information sharing aspects of the Fair Credit Reporting Act.

The California constitutional right to privacy and the California Financial Information Privacy Act (SB1) are explained in Part Five. Topics regarding financial privacy include: what information may be shared with non-affiliated third parties; when an opt-out right must be given under either GLBA, FCRA or SB1; the required contents of the GLBA privacy notice, including the FCRA opt outs that some institutions must provide; and the rules that apply to sharing consumer information with affiliates for marketing purposes.

Part Six of the Manual addresses the important topic of Information Security. This part includes a discussion of the interagency guidance regarding information security standards, the FFIEC’s Cybersecurity Assessment Tool (or CAT), the components of an incident response program, California’s breach notification requirements, and many other related topics.

The main text of the Manual is 238 pages, plus 95 pages of appendices.

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