Bulletin: NY000687

*This is a reissue of STG National Bulletin SLS2023001*

Dear Associates:

Effective January 1, 2023, the California Privacy Rights Act (“CPRA”) expands the rights granted to California consumers under the California Consumer Privacy Act (“CCPA”) introduced in 2018 and which became effective in 2020. The CPRA affords additional privacy rights for consumers that are California residents as well as those declaring domicile in the state of California as defined in the CCPA. Thus, consumers in your transaction involving property outside of California may also be considered California residents for the purposes of CCPA and CPRA.

For example, a buyer with a primary residence in New York is purchasing a condo for their son/daughter in Boston to attend Harvard University and, unbeknownst to Stewart, the buyer also owns other property in California and, under the CCPA’s broad definition, is considered a California resident, the notice would need to be given by the Massachusetts office when issuing its title product regardless of where the closing is taking place.

The introduction of the CPRA places significant requirements on businesses that collect, maintain and/or sell personal information of California residents.

In compliance with the CPPA and CPRA, Stewart has provided an updated Privacy Notice at Collection for California Residents ("Notice"). The updated GLBA Privacy Notice can be found at this link. The CCPA and CPRA are applicable to California residents and individuals declaring domicile in the state of California. As we are unable to determine the exact domicile of an individual involved in a transaction, this Notice is required to accompany Stewart’s GLBA Privacy Notice at all times and on all property transactions regardless of the property state.

In addition to the updated Privacy Notice at Collection for California Residents, we have made updates to our existing GLBA Privacy Notice in compliance with the Gramm-Leach Bliley Act. The existing GLBA Privacy Notice found on Stewart's Virtual Underwriter under the label "STG Privacy Notice 1 (Rev 11/19/13) Stewart Title Companies" is now replaced with the attached and updated Stewart Title Guaranty Company GLBA Privacy Notice.

For Stewart's direct operations and affiliated companies, your strict adherence to this bulletin is required.

For Stewart's independent agents, this bulletin is only intended to provide information regarding the updated laws and regulations and should not be used for legal advice. If, however, you provide Stewart's Privacy Notice in connection with your business, you must update Stewart's Privacy Notice to include the Privacy Notice at Collection for California Residents. This bulletin and its attached links are not otherwise intended to require changes to your internal policies or processes.

In the event you have any questions, kindly contact Stewart Title Legal Services for guidance at 212-922-0050.

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