GLBA And COPPA Audit Case

Overall, the Bank has established sufficient internal controls to provide for compliance with the Gramm-Leach-Bliley Act (“GLBA”), Right to Financial Privacy Act (“RFPA”), Children’s Online Privacy Protection Act (“COPPA”), and California Financial Information Privacy Act (“CFIPA”). In addition, management maintains satisfactory policies, procedures, and processes, and provides suitable job-specific training, and independent compliance monitoring to protect consumers’ privacy.

Issues identified during the prior GLBA and CFIPA audit in 2014 have been sufficiently remediated and the prior audit of RFPA and COPPA in 2011 did not identify reportable issues. The issue identified in this audit is primarily a documentation issue related to procedures