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Monday, August 17, 2015

NAIC -- New look at privacy notices

By ABIA Outside Counsel, McIntyre & Lemon, PLLC

During meetings of the National Association of Insurance Commissioners being held in Chicago, a working group began to consider revisions to the NAIC’s model regulation on health and financial information privacy (PRIVACY OF CONSUMER FINANCIAL AND HEALTH INFORMATION REGULATION — NAIC Model Regulation No. 672). The NAIC is trying to catch up with the federal financial services regulators, who several years ago revised their model privacy notices to establish a “safe harbor,” and permitted the electronic delivery of the notices.

As states adopt the revised model regulation, it will be an important step toward bringing state regulation into uniformity with federal regulation regarding compliance with the Gramm-Leach-Bliley Act’s privacy requirements. This should ease the compliance obligations of bank-insurance marketing.

ABIA will represent its members’ interests as the NAIC revises its model privacy regulation.