April 4, 2019

Missouri to Parallel GLBA Insurer Annual Privacy Notice Requirement

On March 15, 2019, the Director of the Missouri Department of Insurance, Financial Institutions and Professional Registration ("Director") published the final amended Privacy of Financial Information Rule, 20 CSR 100-6.100 ("Rule"). The Rule only applies to Missouri insurers.

The Director amended the Rule to align it with the changes made by Congress to the Gramm-Leach-Bliley Act ("GLBA") by enacting the Fixing America's Surface Transportation Act ("FAST") in 2015 (Pub. L. No. 114-94). These changes eliminated the GLBA requirement for financial institutions to provide annual privacy notices about treatment of nonpublic personal information under certain conditions; and removed duplicative and costly notification requirements for financial institutions.

The amended Rule also deletes "Appendix A - SAMPLE CLAUSES," deletes headings, and makes small non-substantive word changes and deletions. The amended Rule becomes effective April 30, 2019.

Final Notice

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