What is the Gramm-Leach-Bliley Act?
Passed in 1999, the Gramm-Leach-Bliley Act regulates part of the financial services industry. Tax preparers, whether working alone or in firms, are included as providers of financial services (such as banking products). The act took effect in 2001.
Just what constitutes a “clear and conspicuous” form?
The National Association of Tax Professionals (NATP) asked that question of Clarke Brinkerhoff, an attorney in the Division of Financial Practices of the Federal Trade Commission.
The NATP provides an example of what a bare-bones privacy statement might entail for those tax pros who don’t provide services beyond return preparation:
“We do not disclose any non-public personal information about our customers or former customers to anyone, except as instructed to do so by such customers or as required by law. We restrict access to non-public personal information to those professionals necessary to [brief description of service provided ] and we maintain physical, electronic, and procedural safeguards to guard your non-public personal information.”
The Federal Trade Commission publishes a three-page guide for small businesses on compliance with the Gramm-Leach-Bliley Act. It also includes a fillable PDF for use by tax preparers who want a little more than the NATP paragraph.