The amendment to the annual privacy notice requirement went into effect on the date of the bill’s signing, December 4, 2015. Because Illinois law does not include an initial or annual privacy notice requirement, it does not conflict with the exception to the annual privacy notice requirement in the federal Gramm-Leach-Bliley Act.

For resources related to our guidance, please see:

• Public Law 114-94, Title LXXV — Eliminate Privacy Notice Confusion (Exempts from the annual privacy notice requirement 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 . . . .”)