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Reg P Initial Privacy Policy Statement- Signature

Question: 
Does Reg P require the initial Privacy Policy Statement be signed by the client? I am not able to find anywhere that states that is a requirement. If not, how is a bank to document the file that it was given to the client at the time the client established a relationship with the Bank?
Answer: 

by Randy Carey:

There are no signature requirements on a privacy policy disclosure. Like all such disclosures, delivery is proved through your policies and procedures for document delivery. Such as, most doc prep systems for both deposit and loans produce a standard list of documents delivered to all new customers.

Answer: 

by Ken Golliher:

One forms vendor decided it would be a good idea to require an acknowledgement of receipt for its Regulation CC disclosures. So, when examiners found accounts with no acknowledgement, they began writing it up as a "violation." The criticism should have focused on the bank's failure to follow its own procedures, but it was legitimate either way.

It would be unwise to voluntarily expand the requirements of one of the most worthless regulations in the alphabet...

First published on 01/21/2018

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