Under the Gramm-Leach-Bliley Act (15 USC §6803) as implemented by the NAIC Privacy of Consumer Financial and Health Information Regulation (Model 672), an insurer must provide its initial privacy notice to a customer:
Why this is the answer
GLBA Title V (15 USC §§6801–6809) requires financial institutions — including insurers — to (1) provide initial notice of privacy practices when the customer relationship is established; (2) provide annual notices for the duration of the relationship; (3) provide opt-out rights before sharing nonpublic personal information (NPI) with non-affiliated third parties; and (4) safeguard customer information. The NAIC implements this for state-regulated insurers via Model 672. The 2015 FAST Act narrowed the annual-notice requirement: an institution may skip an annual notice if it has not changed its practices and shares only under the §6802(b)(2) joint-marketing or §6802(e) exceptions; otherwise the annual notice continues.
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