Is anybody here using the new privacy notice?
I got an email from a law firm & they want $150 a rooftop for a custom PDF.
Quote below is from Bass Sox Mercer law firm:
“You should have begun using a new privacy notice on January 1.
The Federal Trade Commission and Federal Reserve Board
regulations set forth very specific page layout, content, format, style, pagination and shading requirements. Each notice must be customized to the information collection and sharing practices of an individual dealership. The new form, which is now two pages long, is intended to replace the generic privacy notice your dealership has likely been using for a number of years.”
It appears the new notice was optional until 12/31/2010.
Quote below is from NADA:
“FTC Issues New "Optional" Model Privacy Notice
December 2009 -- As part of a statutory mandate to develop a more understandable template for privacy notices issued by dealers and other financial institutions, the Federal Trade Commission (FTC) and the federal banking regulatory agencies have jointly issued a new model privacy notice that, beginning December 31, 2009, will serve as a safe harbor for the language used in the notice for financial institutions that choose to adopt it.
Dealers who continue to provide their finance and lease customers with a privacy notice that uses language from the sample clauses contained in Appendix A to the text of the original Privacy Rule (which required compliance by July 1, 2001) will lose safe harbor protection for the language used in those notices after December 31, 2010. Accordingly, dealers should consider transitioning to the new notices before the end of 2010.
NADA has links to the final rule containing the new model privacy notice, however the links do not work for me. http://edocket.access.gpo.gov/2009/pdf/E9-27882.pdf
(the amendments to the FTC Privacy Rule begin on page 62,965).
www.ftc.gov/bcp/conline/pubs/buspubs/autoglb.pdf