# NJ DOBI Bulletin 2001-10: Enforcement Requirements of Gramm-Leach-Bliley Privacy Requirements

> New Jersey · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_10

## Section

- **Citation:** NJ DOBI Bulletin 2001-10
- **Heading:** Enforcement Requirements of Gramm-Leach-Bliley Privacy Requirements
- **Jurisdiction:** New Jersey
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** New Jersey Department of Banking and Insurance Bulletins / Enforcement Requirements of Gramm-Leach-Bliley Privacy Requirements

## Text

Bulletin 01-10
BULLETIN NO.: 01-10
TO: ALL INSURERS AUTHORIZED OR ADMITTED TO TRANSACT BUSINESS IN THE STATE
FROM: KAREN L. SUTER, COMMISSIONER
RE: ENFORCEMENT REQUIREMENTS OF GRAMM-LEACH-BLILEY PRIVACY REQUIREMENTS
Bulletin No. 00-15, dated November 8, 2000, advised insurers that the Gramm-Leach-Bliley Act, P.L. 106-102 ("GLBA"), enacted November 12, 1999, requires financial institutions, including insurers, to protect the privacy of consumers� non-public personal information. The Bulletin also advised that Title V of GLBA requires Federal and state regulators to implement GLBA�s privacy protections within six months of the Act�s effective date, except to the extent a later date is specified by the rule. The Act took effect November 13, 2000; however, under the authority of GLBA at section 501(1), Federal regulators delayed enforcement until July 1, 2001.
The Bulletin also advised that N.J.S.A. 17:23A-1 et seq., effective December 7, 1985, regulates the collection, use and disclosure of information gathered by insurers in connection with policies, contracts or certificates of insurance issued and delivered in this State. As noted in Bulletin No. 00-15, in most respects, this statute provides standards that are at least as stringent, and in many cases more stringent, than the standards set forth in GLBA.
The purpose of this Bulletin is to remind insurers that they have been and will continue to be subject to the information and collection disclosure requirements set forth in N.J.S.A. 17:23A-1 et seq, as well as the requirements set forth under GLBA. To the extent that GLBA imposes additional or different requirements than those set forth under New Jersey law in the form or timing of the notice, insurers are reminded that they are required also to comply with GLBA�s requirements. (For example, GLBA requires that notices be sent annually after the initial notice is provided; N.J.S.A
-1 et seq, as well as the requirements set forth under GLBA. To the extent that GLBA imposes additional or different requirements than those set forth under New Jersey law in the form or timing of the notice, insurers are reminded that they are required also to comply with GLBA�s requirements. (For example, GLBA requires that notices be sent annually after the initial notice is provided; N.J.S.A. 17:23A-4 requires periodic notice within 24 months.) In complying with these standards, insurers may utilize those procedures they deem appropriate based on their current systems. For example, insurers may utilize one common notice that complies with both N.J.S.A. 17:23A-1 et seq. and GLBA and may issue one notice or form of notice for all affiliates.
In addition, companies and agents should review their contracts to understand their responsibilities under GLBA. Responsibilities for compliance may be allocated. If the insurer sends the required notices, its agents will not be required to do so, unless the agent(s) separately seeks to utilize or disclose non-public personal information other than in the course of its dealings with the insurer.
As noted in Bulletin No. 00-15, with respect to the enforcement of Federal privacy standards under GLBA, other than those set forth in N.J.S.A. 17:23A-1 et seq., the Department will act in accordance with the delayed enforcement date of July 1, 2001. Insurers should have a plan for compliance by that date. After July 1, 2001, the Department expects to include a compliance review of privacy protections in connection with its periodic examination of insurers.
Finally, the Department will provide further guidance from time to time as issues arise, including promulgation of administrative rules if appropriate.
June 25, 2001
/s/ Karen L. Suter, Commissioner

## Nearby sections

- [NJ DOBI Bulletin 2001-01 Effect of PL 1999, C 275 on Life, Health and Annuity Form Filings](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_01.md)
- [NJ DOBI Bulletin 2001-02 Extension of Time For Submission of Preliminary Applications for Licensure or Certification as an Organized Delivery System](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_02.md)
- [NJ DOBI Bulletin 2001-04 New Jersey Quitnet and New Jersey Quitline](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_04.md)
- [NJ DOBI Bulletin 2001-05 Voluntary Market Written Exposure and Primary Classification Data](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_05.md)
- [NJ DOBI Bulletin 2001-06 New Jersey Mental Health Parity Law](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_06.md)
- [NJ DOBI Bulletin 2001-07 Homeowners Insurance Policies/National Flood Insurance Program](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_07.md)
- [NJ DOBI Bulletin 2001-08 Disclosures Mandated By Federal Regulations Adopted Pursuant To Section 305 of the Gramm-Leach-Bliley Act](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_08.md)
- [NJ DOBI Bulletin 2001-10 Enforcement Requirements of Gramm-Leach-Bliley Privacy Requirements](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_10.md)
- [NJ DOBI Bulletin 2001-11 Invalidity Of Subrogation and Reimbursement Provisions in Previously Approved Contract Forms](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_11.md)
- [NJ DOBI Bulletin 2001-12 Maximum Reserve Valuation and Nonforfeiture Rates](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_12.md)
- [NJ DOBI Bulletin 2001-13 Unsatisfied Claim and Judgment Fund](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_13.md)
- [NJ DOBI Bulletin 2001-14 Disruption and Dislocation Resulting From Tragic Events on September 11, 2001](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_14.md)
- [NJ DOBI Bulletin 2001-15 Use of Affidavit In Lieu of a Death Certificate with Respect to Life Insurance Claims Arising Out of the Tragic Events of September 11](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_15.md)
- [NJ DOBI Bulletin 2001-16 Annual Premium Survey Information](https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_16.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/NJ_INS_B_2001_10. Check the current official text before relying on it. Not legal advice.
