GLBA

Question 1

What is GLBA

Answer 1

Gramm-Leach Bliley Act (Financial modernization act of 1999)

Question 2

What regulation is GLBA?

Answer 2

Regulation P

Question 3

Who regulates the GLBA?

Answer 3

FTC

Question 4

Who enforces the GLBA?

Answer 4

CFPB

Question 5

What is the purpose of GLBA?

Answer 5

1. Advise consumers of policies and use and exchange of personal information
2. Offer consumers the opportunity to limit the use and exchange of that information
3. Create a security program to protect information

Question 6

What are the obligations of GLBA?

Answer 6

1. Provide an initial privacy notice when the customer relationship is established
2. Provide an annual privacy notice for the duration of the consumer relationship
3. Provide OPT OUT notice initially and annually
4. Must provide “reasonable amount of time”
5. Must provide a “reasonable opportunity” to opt out of disclosing NPI (non-public information) to non-affiliated 3rd party
6. NOTICE cannot be Faxed

Question 7

What are the safeguard rules of GLBA?

Answer 7

1. To protect the privacy of personal information with the creation of an effective program concerned with preserving the confidentiality of personal information.
2. Program must be appropriate to the size and complexity of the organization

Question 8

What Act prohibits pretexting?

Answer 8

GLBA

Question 9

What is pretexting?

Answer 9

The use of false pretenses, including fraudulent statements and impersonation, to obtain consumer’s financial information

Question 10

What are the penalties for GLBA?

Answer 10

Financial Institutions $100,000

Individual $10,000 and/or 5 years in prison