Yes, banks that are exempt from the annual privacy notice requirement under the FAST Act’s amendment of the Gramm-Leach-Bliley Act (GLBA) also are exempt from Regulation P’s alternative delivery method requirements.

Regulation P permits financial institutions meeting several preconditions to comply with the annual privacy notice delivery requirement by using an “alternative method” — posting the notice on a website (and mailing it on demand). However, if your bank qualifies for an exemption from the annual privacy notice requirement altogether, you are not required to use the alternative method or any method for delivering the notice.

For resources related to our guidance, please see:

• Regulation P, 12 CFR 1016.9(c)(2) (Alternative method for providing the annual privacy notice.)

• Public Law 114-94, Title LXXV — Eliminate Privacy Notice Confusion (A financial institution that “(1) provides nonpublic personal information only in accordance with the provisions of subsection (b)(2) or (e) of section 502 or regulations prescribed under section 504(b), and (2) has not changed its policies and practices with regard to disclosing nonpublic personal information from the policies and practices that were disclosed in the most recent disclosure sent to consumers in accordance with this section . . . shall not be required to provide an annual disclosure under this section.”)