We are not aware of any rule that requires the font size in the initial privacy notice to be the same as the annual privacy notice. The privacy rules require that initial and annual privacy notices be “clear and conspicuous.” 12 CFR 1016.4(a)12 CFR 1016.5(a). In explaining what “clear and conspicuous means,” the rules state that privacy notices should use a typeface and type size that is easy to read. 12 CFR 1016.3(b)(2)(ii)(B). If you are using the model privacy forms, they must be in “easily readable type font,” with a minimum of 10-point font. Appendix, 12 CFR 1016, Model Privacy Form (see page 8 of the .pdf file, under “3. The Format of the Model Privacy Form”).