Securities Lawyer's Deskbook
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Rules for
Privacy of Consumer Financial Information

Regulation S-P





Rule 18 -- Effective Date; Transition Rule


  1. Effective date. This part is effective November 13, 2000. In order to provide sufficient time for you to establish policies and systems to comply with the requirements of this part, the compliance date for this part is July 1, 2001.


    1. Notice requirement for consumers who are your customers on the compliance date. By July 1, 2001, you must have provided an initial notice, as required by Rule 4, to consumers who are your customers on July 1, 2001.

    2. Example. You provide an initial notice to consumers who are your customers on July 1, 2001, if, by that date, you have established a system for providing an initial notice to all new customers and have mailed the initial notice to all your existing customers.

  2. Two-year grandfathering of service agreements. Until July 1, 2002, a contract that you have entered into with a nonaffiliated third party to perform services for you or functions on your behalf satisfies the provisions of Rule 13(a)(2), even if the contract does not include a requirement that the third party maintain the confidentiality of nonpublic personal information, as long as you entered into the agreement on or before July 1, 2000.


Regulatory History


65 FR 40334, 40371, June 29, 2000



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