This past June, the Rhode Island Department of Business Regulation adopted revisions to R.I. Admin. Code 11-5-99, Sections 5, 7, and 8 of which require certain privacy notices to be provided by licensees under the Banking and Insurance Consumer Protection Act to customers (individuals with an established relationship with the licensee) and consumers (individuals seeking to obtain an insurance product, but who do not have an established relationship) who seek to obtain an insurance product from the licensee.
Appendix A of Ibid. provides sample clauses which may be included in the notices and, based on these sample clauses, we have drafted the necessary documents which any of our clients, who are licensed under the Banking and Insurance Consumer Protection Act, may provide in their Initial packages.
Basically, there are three types of notices, either of which may be given depending on the practices of the licensee. One is a “Nonsharing” version (Cx17887), which is to be provided if the licensee does not share any of a customer’s nonpublic personal financial information with anyone. Another one is a “Sharing” version (Cx17888) which is to be provided if the opposite is true. The third version is a “Short” version (Cx17889) which can be provided to consumers informing them that the licensee’s privacy policies are available upon request.
These three documents are available upon request, since most (if not all) of our clients are not licensed under the Rhode Island Banking and Insurance Consumer Protection Act. Once requested, they will print in Initial Disclosure packages.
Due to the varied nature of these documents, which will need to print client-specific information on them which is not passed to us from any LOS, any client who requests these documents will be directed to our Legal Department, who will work with them in disclosing the appropriate information on these documents.
These documents are available immediately. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
December 23, 2013