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Partnership Passbook Savings USA Patriot Act Payday Loans Payroll/Payroll Cards PC Personnel Pharming/Phishing Photocopies Photocopying ID PIN PMI Pledge/Pledging POD Polilcies Polygraph Positive Pay Post-dated Checks Power of Attorney Predatory Lending Privacy Promotional Incentives Proof and Transit Public Funds denotes Guru Question & Answer. Partnership Cashing a Check Made Payable to a Partnership Partnership Account with a POD Spousal Partnership Opening a NOW Account LLC & LLP Loan Documentation Rescission on property titled in LTD Partnership Signatures required on loan to partnership Reg O and minority partnership interests Documentation for a Joint Venture Account LLP Filings Who Closes a Partnership Account? Disputed Access to Business Account Account Styling: Converting a Partnership Account to a Sole Proprietorship Account Partnership Name and Filing UCC Documents Passbook Savings Increasing Savings Account Deposits a Must Disclosing Fee for Withdrawal Customers and their Passbooks Are Statements Required for Passbook Accounts? Periodic Statements on Passbook Accounts with EFTs Reg DD disclosures for Christmas Club Accounts Overriding lending policy Statement Requirements For Passbook Savings Account USA PATRIOT Act Avoiding AML and OFAC Risks Five Reasons for Identity Verification in 2008 Effective Date of CIP Physical Address Rule Evolution of OFAC Guidance Since 1996 Updated OFAC Penalties, Fines and BIS Watch List Non-Compliance When should the Bank file a Suspicious Activity Report (SAR)? PEP List Scanning For Your Customers Check Privacy Issue Say Uncle? PEPs and Potential Risk Spreading the Word about Fraudulent Activity OFAC�s Multiple Watch Lists Using Risk Analysis for Efficient Compliance Programs Setting Scoring Thresholds Based on Risk for Automated Customer Identification Program (CIP) Screening Software Tools Managing Identity Risk USA PATRIOT Act Confusion CIP - Church Youth Group Account OFAC Check on Seller of Property ID and Re-ID for CIP? Patriot Act ID Verification on the Other Owner Cash an On Us Check for Person on the OFAC List? ID for the Patriot Act Changing Signatures on Business Accounts CIP - Privately Held Co. Owned by Publicly Held Co Member of Publicly Traded Company Exempt from CIP? Privacy and the USA PATRIOT Act Service v. OFAC? CIP Rules for ID SAR for Disecrepancies in Employment Application? Service to Help Identify Customers "Yes, That Check Will Clear," Violating the USAPA? CIP on Pre- Patriot Act Customers BSA Exam Procedures for CIP CIP Business Accounts A Theory About Bank Robbery CIP ID Requirements for Out-of-State Signers Guru Compilation: CIP (PDF) Ongoing Reviews and SAR Follow-Up Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One Copy of ID in Loan File OK? CIP Use of a P.O. Box for Mail CIP Rules Define 'Customer' Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One CTRs on Checks Cashed by Noncustomer Payee Checking the OFAC List on Cashier's Check Purchase Board of Directors Liability Help Arrives - Just In Time: Section 326 Compliance, OFAC Check and Fraud Protection in One Pass Branch Robbery in Homeland Alert Times Why Require a TIN for an Irrevocable Trust? Explicitly Mentioning the PATRIOT Act on Lobby Notices Verifying Residence Address Prohibitions on Copying Driver's Licenses How can I establish a compliance program in response to the USA PATRIOT Act? BSA Enforcement Using the FinCEN Information Request List CIP and Denials PATRIOT Act: Section 312, PEPs, and Senior Foreign Political Figures Money-Laundering or Terrorism: What Are We Looking For? Documentation of 314(a) Searches Evaluating Fraud and PATRIOT Act Solutions FinCEN, the information sharing certificate, and program elements BSA Compliance Matters Evaluating Fraud and PATRIOT Act Solutions E-filing your BSA reports (PACS) OFAC & PATRIOT Act Deadlines: What can wait? What's the difference between KYC & CIP? Section 314(a) Records Requests USA PATRIOT Act: Credit Card Cash Payment Limit? Verifying The SSN & CIP IDENTITY CHEK compliant with newly released Section 326 of the USA PATRIOT Act Mutual Banks, Customers, and Section 326 -- Lexis/Nexis Retention of Loan Customer Driver's License Info 314a Documentation Spreadsheet BOL Letter to FinCEN re 314(a) Requests FinCEN Letter to BOL re 314(a) Searches Handling A Hit On The Terrorist Watch List USA PATRIOT ACT: When does our CIP Program have to be in place? Preparing for Section 326 CIP Program Implementation Deadline CIP Compliance Delayed Life After The Moratorium 314(b) Information Sharing Update FinCEN List Nuts & Bolts Identity Theft and the USA Patriot Act Will we need to obtain a copy of a driver license for a guarantor on a loan? USA PATRIOT Act: ID Requirements For A Minor USA PATRIOT Act Account Opening Worksheet Adequate Advance Notice Under Section 326 PATRIOT Act AML Rules The USA Patriot Act and the Sleeper Provision USA PATRIOT Act Payday Loans Registering MSBs Payday Lending, Risk, & Regulators Predatory Practices Come Under Regulators' Microscope PayDay Loans "Payday Loans" Make The News Payroll/Payroll Cards CTR Completed in the Name Of? Payroll Check Signed by Entity CTR - Employees Cashing Payroll Checks File SARs for Significant Cash Withdrawals? Using Payroll Accounts to Avoid Summons Reg E - Direct Deposit of Bank Employee Payroll Minor Payroll Check Cashing OFAC - Cashing Non-Customer Payroll Checks Rules for Customers to Obtain Payroll Cards Payroll Card Use Growing Rapidly An Innovative Payroll Card More Payroll "Cards" Payroll Cards PC "Next, Please?" Personnel Help Wanted 3 Keys to Building a Solid Team Employment Application Info for Background Check Overtime Rule Changes Impact Banks Background Checks on New Hires Family and Medical Leave Act French Bank Employees Have Stress Reliever Treatment of Departing Employees Requiring Direct Deposit for Employment Conflicts, Problems Could Be Helped with Solutions from Mediation Work Employee recognition can be as simple as saying �Thank you� Affirmative Action Plans for Banks Is this Discrimination? September 11 Doesn't Justify Discrimination Against Muslims, Arabs, Others Legal Issues in RIFs Janitors and Privacy Issues September 11 Doesn't Justify Discrimination Against Muslims, Arabs, Others Planning and Executing a Reduction in Force Criterion to Evaluate Operations Staff Reviewing Unusual Activity in Employee Accounts Hiring correctly can be boiled down to three simple steps Is Hiring on the Basis of Appearance Illegal? How to Investigate Sexual Harassment Complaints EEOC Settles Same-race Discrimination Complaint Legal Issues in RIFs Employee's Deceit Voids FMLA Protection Informing Employees of Embezzlement What Shall I Wear To Work Today? Sharing your calendar Employee anniversary parties Time management tips Use the carrot instead of the stick Neatness Counts Question & Answer EDITORIAL - An Auditor's Nightmare IN THE NEWS - Help Wanted IN THE NEWS - Jobs Depend On Test Results Question & Answer WHAT DO OTHER BANKERS DO? - A Very "Fair" Way to Hire WHAT DO OTHER BANKERS DO? - Banks Good Places For Working Moms Are You In Compliance? IN THE NEWS - Ten "Not Nice" Statistics WHAT DO OTHER BANKERS DO? - Paying Up To Dress Down A Drug Problem? In My Office? No Waya! Can You Be Bought? Employee Handbook Employee Handbook IN THE NEWS �Banker For Hire Question & Answer She Used To Work For You To "Dress Down" Or Not ? That's The Question ! Vacation Policies & Procedures WHAT DO OTHER BANKERS DO? -What Shall I Wear To Work Today? Bankers & Ethics It Was Bound To Happen "No Meetings Scheduled For Thursday Afternoon?""Good!"�"Let's Have One!" George's Point Of View George's Point Of View�"It's The People" George's Point Of View�Casual Dress Up! Question & Answer Question & Answer FDIC Improvement Act Of 1991 Mandates Major Change Question & Answer PERSONNEL VIGNETTES: Delegating Responsibility PERSONNEL VIGNETTES: Delegating Responsibility (Part One of Two) Personnel Vignettes:Temporary Solutions�Permanent Problems? PERSONNEL VIGNETTES-Shopping For Temporary Services Practical Application Question & Answer Signs Of The Times "Perception�Becomes Reality" Affirmative Action Interviewing: Do's & Don'ts Layoffs Controlled On Asking Questions PERSONNEL VIGNETTES: "That's All I Can Tell You..." PERSONNEL VIGNETTES: "Th at's All I Can Tell You�" Personnel Vignettes: DISCIPLINARY ACTIONS-Five Steps For Dealing With A Problem Employee Personnel Vignettes-We All Discriminate PERSONNEL VIGNETTES-Why Good People Leave Jobs WHAT DO OTHER BANKERS DO? - Involve ALL The Employees! A Personnel Nightmare (Part I) A Personnel Nightmare (Part II) Don't Tempt The "Temps" First-Document Patience, Patience, Patience PERSONNEL VIGNETTES - The Titanic Syndrome Truth or Fiction? Fingerprint Reports Expanded Mandatory Fingerprinting? Fingerprinting Questions & Answers Pharming/Phishing What is the Difference Between Pharming & Phishing Vishing and Smishing Bank Employees' Role in Phishing Protection Is there an Identifiable Geographic Risk Factor in Online Fraud? What is the Difference Between Pharming & Phishing? Selling Account Monitoring Phishing by Debit Card CU Responsible for Member�s Loss to Phishing Scam? More Scams using FDIC Fraud, FDIC and FACTA Keeping Online Banking Safe: Why Banks Need Geolocation and Other New Techniques Right Now Does IM Pose a Security Risk? Internet Account Compromised, Who Eats the Loss? Phishing Scams Increase 180% in April Alone! Could Someone Successfully "Phish" for Your Customers? Phishing Scams On The Rise Photocopies Copy Credit Cards for CIP Documentation CIP Proof in the File High-End Copiers May Be a Security Gap Copy of Green Card in the Loan File If Transactions are Over $3,000, Make a Copy? Legalities of Copying a Driver's License Destroy the Originals but Keep the Scanned Copies Reg CC 's Endorsements Printed in Black Ink Rule Scan the Signature Card, Keep the Original? Annual Privacy Notice on Deposit Statements Keeping Photocopies of Sold Loans Attempted to Deposit a Photocopy of a Check Federal Reserve Banks Make Check 21-related Announcements Evidence & The Security Officer Photocopying Treasury Checks Returning Imaged Copies Photocopying ID CIP Proof in the File Copy of Green Card in the Loan File Copy of Drivers License in the Credit File BSA - Copying Driver's License for Each Loan Customer Won't Allow Bank to Photocopy License CIP - Retaining Photocopy of Customer Credit Card Keeping Copies of Drivers Licenses with Loan Docs Copy of SSN Card Section 326 Revisited Photocopying and Foreign ID Directives Considered Copying driver's licenses Can I make a copy of an SSN card? Copy of ID in Loan File OK? Prohibitions on Copying Driver's Licenses USA PATRIOT Act: CIP & Photocopying The Driver's License Photocopy Of A Photo ID, Reg B, And "Discrimination in Lending" Photocopying The Driver's License: Sometimes it IS acceptable Photocopying Treasury Checks Photocopying A Driver's License For Identification Photocopying ID: What Regs Does This Violate? PIN Multiple Cards, One PIN? Customer's Recourse with Merchant Credit Account for ODs from Lost ATM Card? Reg E - Stolen Debit Card Stolen Debit Card - PIN Written on Checkbook Changing ATM Service Providers Consumer Liability for Negligence in PIN-Handling ATM Dispute Claim Reg E Claim Denied - Re-Evaluated for Bank Officer Customer Gave PIN Number to Family Member Customer Hasn't Checked Statement Since Nov 2005 Phishing by Debit Card Unauthorized Use of Check Card & Customer liability Is Customer Responsible if PIN is on the Card? Handy PIN Fighting Back With Education Is MasterCard SecureCode Subject to Reg. E PMI Final TIL - PMI Tax Included? Raising LTV Percentage HPA & Mortgage Loans with PMI Annual PMI Notice PMI at Closing -- Prepaid FC? PMI Disclosures On The Settlement Statement PMI & Sale of Insurance Disclosures PMI Premiums, Payment Schedules, and Adjustable Rate Mortgages PMI Requirements Disclosing PMI Premiums Adding PMI to a Note Private Mortgage Insurance Pledge/Pledging Negative Pledge of Assets Real Estate & 1098 Forms Loan to spouse considered loan to EO? What "Note" Makes it HMDA Reportable Pledging Securities to Secure Customer Deposits Disclosure to Cosigners Pledging a Jointly Owned CD as Collateral Using An IRA As Loan Collateral Requiring All Owners Of Jointly Held Accounts Used As Collateral To Sign The Security Agreement Pledging Assets As Security For Deposits Of Public Funds Loan To A Living Trust: Required Documentation Savings Bond as Collateral Home Equity Loans For Property Owned By A Living Trust Reservist Achieves Victory Under SSCRA: What Every Lender Should Know POD Beneficiaries Disclaiming Account Ownership POD Designation & Probate Deceased Customer -Stolen Debit Card Transactions POD's Whereabouts Unknown Partnership Account with a POD List Spouse as "Survivor" not as POD? ITF & POD Beneficiary Designation Beneficiary Information for POD or ITF Accounts Account POD to Minor Living in Another State OFAC on the Beneficiary of a POD Account? What's the Difference Between a Totten Trust & POD Offset of Account with a POD Beneficiary POD Beneficiary Signing Security Agreement Authorized Signer Designated as a POD Beneficiary Non USA Citizen as a "POD" Power of Attorney remaining as a POD beneficiary FBO Accounts Check Fraud on Deceased Customer's Account POD CDs: Handling Interest after the Customer has Died Minor as POD Beneficiary? POD on Safe-Deposit Lease POD on an LLC Can a corporation have a POD beneficiary? Owning Accounts After Death of Depositor POD Beneficiary and CIP Pledging a Jointly Owned CD as Collateral How should we handle uncashed CD interest checks for a deceased customer? Adding A Living Trust As POD Can a Totten Trust trustee give POA for transaction authority? Can an authorized signer be designated as the POD beneficiary? Is there a difference between "beneficiary" and P.O.D.? Adult Beneficiaries On A Minor's Account Are the terms Payable on Death (POD) and Beneficiary interchangeable? POD Account Regulations CDs, POD Designation, and Beneficiaries Is there a limit to the number of POD beneficiaries that an accountholder can list on a CD? Is it permissible to allow the AIF to add themselves as POD beneficiary? Can a safe deposit contract have a POD clause? Showing POD Beneficiaries Allowing Contingent POD on a CD: Is this wise? What is the the difference between "ITF" and a "POD"? POD Designations on Safe Deposit Boxes Can a Sole Proprietorship Account Designate a POD? Can a person's legal guardian set up a POD account with the guardian as beneficiary? Policies BSA Retention Policy & Loan Documents Privacy policy and Security Statement About the Bank Secrecy Act Enforcement Policy Executive Officer Kidnap Policy Dry Dock Slip as Collateral Flood Zone & Insurance Policy Conflict Minimizing Risk Consumer Loan Underwriting Standards Proof of Privacy Policy Disclosure Branch Isn't Following OFAC Procedures Talkative Teller Secondary ID Bank Policies Approved by the Board Is Opt Out Required in Privacy Policy? Compliance Procedures LLC & LLP Loan Documentation IT Security Checklist A Checklist of Ten Steps to Preparing for the Examiners I'm Looking for a Compliance Policy Template Effective IT Policies CRA Officer Policy and Procedures PDA Policy Examples of Collection Letters CRA & HMDA Policies Required? Need a Template or Sample E-Sign policy Uniform Retail Credit Classification Policy Updating Loan Policy to Reflect FACTA Changes Compliance Signposts Policies for Online Banking Procedures for bankruptcies AML Policies, Procedures for an MSB Limit for a Personal Money Order? Annual policy reviews Risks should be assessed before marketing via e-mail Employee Overdrafts Board Approval of Policies Writing a Policy Written Policy: Using Rubber Stamps For Signing Business Checks Written Security Program Required Naming BSA Officer in Your Policy Ten Tips for Writing Bank Policies Employment Policies Reviewing Unusual Activity in Employee Accounts Modifying Policies to Fit Online Banking Finding a List of Required Policies Separate Policy for Internet Banking? KYC vs. CIP EEOC Settles Same-race Discrimination Complaint Overriding lending policy Flood Compliance Policy Guidance Good Address Change Procedures Information Technology Policies Wanted Wanted: Sample Code of Ethics Policy Kidnapping, Extortion and Bomb Threat Policies Fraud Prevention Incentive Plan For Employees Damage Control Eliminating Branch Opening Procedures and Time-Delay Vaults Internet and/or Technology Incident Response Sample Policies & Procedures Record Retention Policy Guidelines Sample Hacking Incident Policies Sample Investment Policies Sample Information Security Policy Sample Compliance Policies Developing a Branch Closing Policy Polygraph Polygraph Pitfalls Polygraph Testing? Positive Pay Untimely Positive Pay Exceptions Shifting onus for unauthorized items to customer Expanded Positive Pay Capabilities Positive Pay Solution Required Use of Positive Pay Positive Pay & Fraud A New Degree Of Verification Positive Pay For Smaller Companies Positive Pay Implementations: Expected Duration and Cost Positive Pay Investment: Is it Worth it For My Customers? "Catch Me If You Can" The Top 10 Reasons Your Customers Say They Don't Need PayPositive And Why They Are Wrong! Problems With Positive Pay? No Way. Value-Added Benefits of Positive Pay Check Fraud is an $18.7 billion "business". How much of it is yours? Check Fraud and the New UCC: Why You Need to Care Enhanced Check Fraud Security Post-dated checks Cashing Post Dated Checks UCC: Practical Application, Part II Guru Chatter on Check & Deposit Issues (PDF) Responsibility For Post Dated Checks Status of Stale Dated/Post Dated Checks Question & Answer Power of Attorney POA & Joint Demand Deposit Account POA Check Deposit Procedures POA CIP Requirements POA Powers & Safe Deposit Boxes POA on a Trust Account UTMA & Minor Saving Accounts POA Documentation POA Added on a Minor Account? Power of Attorney Appointment POA on a Revocable Trust Account POA Responsible for Filing Taxes? POA Safe Deposit Box Entry Proper Endorsement of POA Power of Attorney remaining as a POD beneficiary Adverse Credit Reports on Authorized Signers Issuing a Debit Card to POA on an Account Power of attorney and LLC Depositing to Another's Account with a POA Corporate Account: Multiple Signers with No Signature Cards Power of Attorney Abuse Can an "S-Corporation" have a Power of Attorney (POA) sign on it? Appointing A POA To A Living Trust Guru Compilation: Power of Attorney(PDF) Living Trusts & POA Agent Transferring Funds To Own Account Account for Institutionalized Customer Power of Attorney Issues Safe Deposit: What is the holder of a POA authorized to do? Can Executor/Administrator Grant a POA? Requiring Original POA Document To Open Account Filing A CTR When A Power of Attorney Is Involved Can a Totten Trust trustee give POA for transaction authority? Delegating Responsibility For The Custodian Of An Account Who's Got The Power? Retention Requirements: POAs & Death Certificates Safe Deposit: What is the difference between a Power of Attorney and an Appointment of a Deputy? Can an individual IRA accountholder grant a Power of Attorney to a third party? Can an IRA owner have a Power of Attorney on his/her IRA? Can a Power of Attorney be used for an IRA? POD CDs & FDIC Insurance Coverage Trust Accounts & Power Of Attorney Could you tell me if a Bank Customer must have a "Power Of Attorney" which was drawn up by an Attorney? Who is the owner of a POD account? A custody account? Can an account established under the UTMA also have a POD? POA & Joint Accounts Power Of Attorney Signed With An X: Is it good? Power of Attorney Limitations Documenting Power of Attorney Who's Got the Power? Predatory Lending Not So Fair Lending? FBI Reports Mortgage Fraud Running Rampant Predatory Lending: The Study and a Verdict OCC Speaks Out on Consumer Complaints A Closer Look at Overdraft Privilege Programs OCC Issues Guidance on Predatory Lending Fair lending & auto loans Reg Z Section 32 Clarification Sought Payday Lending, Risk, & Regulators Are We Looking At The Right Stuff? Time Restriction Before Refinance Can Occur Predatory Lending: Lessons Learned Negotiated closing costs & no-closing cost loans Predatory Lending under Regulatory Scrutiny Predatory Lending Practices Result in Large Settlement Treasury's Efforts to Stop Predatory Lending Is the capitalization of interest on home equity loans prohibited? Is it predatory? Bank Liability in the News Predatory Lending - The Regulators' Response Predatory Lending - What Is It? Predatory Lending: Unfair & Unsound Educate to Curb Predatory Lending Looking for Predatory Signals Who Is Responsible for Stopping Predators? What Happens When Consumer Advocates Mean Well? Warning About Predatory Lending Using Compliance to Combat Predatory Lending CRA and Subprime Placing Hopes on HOEPA FRB Issues Proposal to Expand HMDA Reporting Measuring Predatory Lending OTS Studies Subprime Lending Predatory Lending Self-regulation from FNMA Predatory v. Subprime COMPLIANCE NOTES - FTC Brochure on Predatory Lending COMPLIANCE NOTES - OCC and Predatory Lending Privacy Rules The Consumer's Perspective COMPLIANCE NOTES - Privacy Policy Staying Away from Predatory Lending Predatory v. Good Lending: Comparing What's Wrong with What's Right COMPLIANCE NOTES - Agency Heads Testify on Predatory Lending COMPLIANCE NOTES - Tanoue Criticizes Predatory Lending Raises Compliance Issues Subprime Lending Risk v. Profit Credit Reporting A Pet Peeve from Hawke Privacy Clean Desk Act Member FDIC Required on Privacy Disclosures? Privacy Regs and "Tell a Friend" Marketing Program Five Reasons for Identity Verification in 2008 Website Speed Bumps Certificate of Compliance Guidance Needed Privacy - Is Vendor an Affiliate? Video Surveillance Warning Annual Privacy Notice to Businesses Privacy policy and Security Statement Maintaining Confidentiality Signing for Disclosures Debtor's Privacy & Guarantor Notification Co-borrowers Liabilities & Credit Reports Third Party Privacy Hold Privacy and Drawings Proof of Privacy Policy Disclosure Privacy Act - Account Numbers on Back of Checks Spouse's Access to Mortgage File Opt-out Disclosure Required? Talkative Teller Bank Info Required on Privacy Notices? Non-customer IRS Summons RFPA - IRS Requesting Info on Loan Customer Is Opt Out Required in Privacy Policy? Privacy Laws & Marketing to Non-Customers Reg P Annual Vendor Review Consolidation Loan for Medical Bills Check Verification & the Privacy Act SAR: Staff Member Disclosed Client Info to 3rd Party Handling a Breach of Customer Privacy Discussing Loans with Father of Debtor, Privacy Violation? Opt-Out Procedures for Additional Account Privacy Issues & Combined Statement Annual Privacy Notice on Deposit Statements Privacy Issue When Paying Off a Spouse's Loan Selling Account Monitoring Protecting Customer's Medical Privacy Is a Privacy Notice Required for Loan Guarantor? ATM Privacy Notice Evaluating the Security of Online Collaboration Vendors FDIC Issues Guidance on Instant Messaging Banks Trusted by Consumers on Internet Privacy Privacy and the USA PATRIOT Act Privacy, Compliance, and Disclosures Refusal to Verify a Check Under Privacy Sharing Kiting Info with the Other FI Customer Says "Opt Me Out or Else!" Verifying Checks Over the Phone "Yes, That Check Will Clear," Violating the USAPA? "The Check is NSF": A Privacy Violation? s Privacy Notices for Safe Deposit Boxes FACT Act and customer privacy: To disclose or not to disclose? Fraud Cases -- Providing Records to Police Getting Customers to Sign Night Bag Log Statements for the Disabled Bank Supervision: Information Sharing with Europe Customer Referral Rewards Program Mailing Annual Privacy Notices Are your Internal Controls like Swiss Cheese? Part 13: Branch or Department Keys Service of Tax Levy or Garnishment Papers Does IM Pose a Security Risk? Privacy Notices to Shareholders How Much Can Privacy Statement Change w/o Notice? Storage Security: How To Ensure Confidentiality of Data on Backup Tapes On-Site or While Stored Off-Site? Privacy and Outsourcing Loan Reviews HUD 1/1A and Privacy Bundling Required Notices Disclosure of Confidential Customer Information Reg. CC and Privacy Excuses for Non-Availability Privacy notice with mortgage affiliate Ensuring Compliance with Third-Party Vendors Ongoing privacy training Employee Overdrafts Deposits Made By Person Not On Account On Privacy� Recipients of Annual Privacy Notices Janitors and Privacy Issues