Regulation S-P: Disclosure Limitations, Exceptions, and Safeguarding
Chapters in this video
What this video covers
- The four mandatory conditions for disclosing nonpublic personal information (NPI) to a nonaffiliated third party: initial privacy notice, opt-out notice, reasonable opt-out opportunity, and the consumer not having opted out
- Why missing any one of the four conditions blocks the disclosure entirely, absent an exception
- The service-provider and joint-marketing exception and its strict contractual purpose limit on how the third party may use the data
- The processing and servicing transactions exception and why it lets a firm skip the four-step gauntlet to execute a client-authorized trade
- Why "other exceptions" is a closed list of exactly seven enumerated items (consumer consent, fraud protection, legal compliance, consumer reporting, business sale or merger, and others), not a broad catch-all
- The written incident-response program's required components: assess, contain, notify, plus mandatory service-provider oversight through due diligence and monitoring
- The 72-hour service-provider notification clock to the firm versus the 30-day firm notification clock to affected customers, starting from the firm's awareness of the breach, and when each duty can be waived or delayed
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