The Gramm-Leach-Bliley (GLB) rules are particular about what your Privacy Notice says. Using the correct model form will avoid confusion.
More importantly, you MUST DELIVER THE FORM BEFORE YOU SHARE ANY INFORMATION ABOUT A CUSTOMER WITH AN AFFILIATE OR PARTNER. So before you register your loan with a wholesaler, submit for pre-approval, and order an appraisal, etc., etc.
We see many companies using older, cribbed, or outdated privacy notices. While it is possible to create a form that says the same things as the model notice, do yourself a favor and use the Model Form. Most LOS' have the form built in. If they don't, you can create yours right here on the Federal Reserve Form Builder Tool:
Some states have very specific language requirements in the privacy notice, such as Vermont: