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The Bank’s understanding is that there is no longer a requirement to send an annual privacy notice if the Bank has not made any changes to its privacy policy or does not share information, as well as if such notice is available on the Bank’s website. The Bank also understands that even though the law has changed to this effect, there are no final rules issued by the banking regulatory agencies implementing such. Is the Bank’s understanding correct? The Bank includes a message in periodic statements indicating that the privacy notice is available on the Bank’s website. Is the message on the periodic statement still required?
The Bank is preparing to comply with the new Beneficial Ownership Rules and is receiving mixed messages regarding family trust accounts. Do the Beneficial Ownership Rules apply to family trust accounts that do not register with the state?