Gramm-Leach-Bliley privacy notice update

July 10, 2003

With a federal district court decision expected in mid July on the FTC's application of Gramm-Leach-Bliley Act (GLBA), the FTC has indicated it does not intend to bring enforcement actions against lawyers for failing to comply with the notice provisions prior to the court's forthcoming decision.

The FTC's decision is in response to the New York State Bar Association (NYSBA) and the ABA, each of which have challenged the application of GLBA for lawyers. The NYSBA and ABA expressed concern that lawyers who provide real estate, tax, and any other financially related advice to individuals and are covered by the FTC's interpretation of the privacy provisions of the GLBA faced a dilemma because the court had not ruled yet.

• Message from ABA - Carlton Letter
• Letter from the FTC to David Roll and Warren Dennis 22 KB abanet.org
• Federal Focus: Gramm Leach Bliley Update Capitol Update June 16, 2003
• Gramm-Leach-Bliley Act ftc.gov
• State Bar of Wisconsin agrees with ABA and New York Bar; law firms are not "financial institutions" Wisconsin Lawyer November 2002
• Law firms must send privacy notices to clients by July 1 Wisconsin Lawyer July 2001