Cx1227 has been provided over several decades to fulfill the requirements of several Federal privacy laws, including the Gramm-Leach-Bliley Act and Regulation P (12 CFR Pt. 1026).
In 2011, Regulation P was revised and set forth a new privacy policy form (see 12 CFR Pt. 1016, App.) which provides a “safe harbor” of compliance to a financial institution who properly utilizes such form. DocuTech created this model form (Cx15182) at the time but, due to the complexities of setting up defaults for the document to utilize it properly, we continued to provide and maintain Cx1227 for clients who preferred the simplicity of this form to Cx15182.
In order to streamline processes and ensure that clients are provided a “safe harbor” of compliance in regards to Regulation P, Cx15182 will now be the only standard privacy notice we support for compliance with Regulation P. Cx1227 will still be available upon request, but it will be considered a custom document rather than a standard one and will no longer be warranted by DocuTech for compliance.
Cx1227 will be assigned to clients who have printed it over the past 90 days (and have not also printed Cx15182). If clients set or map the field entitled “Print 2011 Model Privacy Policy Notice” (Field 48670) to “Yes,” Cx15182 will print in lieu of Cx1227.
The configurations for Cx15182 will also be modified so that it will print when Field 48670 equals “Allow Any,” thus it will print in all Initial Disclosure packages for all other clients.
These changes will take effect on May 21, 2015. Clients who wish to change their defaults for Cx15182 should contact their Account Manager. For all other questions, concerns, or inquiries, please contact Client Support at 1.800.497.3584.
May 14, 2015
DR 169406