Authorities Regarding GLBA Privacy and the FCRA

One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and the FCRA. Regarding GLBA privacy, we are posting OCC interpretative letters 910 and 917, which remain basic authorities for the interpretation of Section 12. Regarding FCRA, we are posting two letters – “Tatelbaum II” and “Gowen” – which are still key in the interpretation of Section 604(a)(3)(A). Links to all these letters will appear on the Privacy and Data Security Resources page, under the headings Gramm-Leach-Bliley Act and Fair Credit Reporting Act, respectively. Further such authorities will be posted there from time to time.