When the Consumer Disclosures (D) Working Group met in Seattle in August, it adopted a model bulletin that clarified that insurance companies may use the new Federal Model Privacy Form – or continue to use other types of privacy notices that differ from the Federal Model Privacy Form – in order to meet state privacy requirements. It was further noted during that meeting that companies choosing to use the new federal form would be granted a safe harbor of compliance with state privacy notice requirements to the extent that the notice requirements are consistent with the privacy notice requirements of the federal Gramm-Leach-Bliley Act. The new model bulletin will be considered for adoption by the NAIC Executive Committee/Plenary during the Orlando meeting next week.
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