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The Vermont Department of Financial Regulation recently issued revised regulations regarding annual privacy notices, effective March 15, 2018.
A financial institution is not required to deliver an annual privacy notice if:
If a financial institution has been excepted from delivering an annual privacy notice and changes its policies or practices in such a way that it no longer meets the requirements for the exception, the financial institution must provide a new privacy notice to customers at least 60 days prior to the effective date of the changes in its policies or practices. The new privacy notice will be treated as an initial privacy notice for purposes of this regulation and the financial institution’s obligation to provide an annual privacy notice thereafter shall be determined in accordance with the requirements and exceptions of these provisions.
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