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GLBA Violation-Loan Info Displayed on File Cabinet
Answer by Randy Carey, BOL Guru
Guru Bio
Question: Is it a GLBA violation if a list of loan numbers with the borrower's name next to it is posted on a file cabinet that is visible in an office facility?
Answer: The disclosure of the fact that any individual is or has been a customer of the bank to a non-affiliated third party violates the privacy regulations. 12 CFR 216.3(o)(2) (i) Information included. Personally identifiable financial information includes: (C) The fact that an individual is or has been one of your customers or has obtained a financial product or service from you.
First published on BankersOnline.com 5/12/08
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