Agencies Clarify that GLBA Disclosures Need Not be Provided at Pre-Existing Insurance Policy Renewals.

Mondaq Business Briefing, April, 2003

The four federal banking and thrift agencies clarified that the insurance consumer disclosure required by the Gramm-Leach-Bliley Act of 1999 (the "GLBA") and the agency regulations promulgated thereunder need not be provided upon the renewals of insurance policies initially sold before October 1, 2001 ("pre-existing policies"). In an August 17, 2001 letter (see the August 28, 2001 Alert), the agencies had said the disclosures "should be made" upon such renewals. However, in light of information provided by bank trade associations highlighting that the GLBA itself did not mandate disclosures upon renewals of pre-existing policies, and the burden and impracticability of actually providing those disclosures, the agencies changed their view.

OCC Takes Enforcement Actions...