Is a privacy notice required when a customer has a continuing relationship with a financial institution?

A privacy notice is indeed required when a customer has a continuing relationship with a financial institution, as stipulated under the Gramm-Leach-Bliley Act (GLBA) regulations. The GLBA establishes that financial institutions are obligated to provide privacy notices to customers to inform them about their information-sharing practices. This requirement holds true whether the relationship is for a single transaction or ongoing engagement, underscoring the importance of transparency regarding how customer information is collected, used, and shared.

The privacy notice serves several key purposes: it notifies customers of their rights, it explains the types of personal information collected, and it outlines how that information can be used or disclosed. This is essential for building trust and ensuring compliance with privacy laws, while also giving customers the ability to make informed choices about their personal information.

Notably, the requirement is not contingent upon whether the customer explicitly requests the notice. It is also relevant regardless of whether information is shared with third parties, as the GLBA's emphasis on protecting customer privacy applies broadly to all aspects of the financial relationship. Thus, the obligation to provide a privacy notice exists independently of the nature of the transactions or the sharing of information.