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Sharing Customer Info with Bank’s Brokerage Firm
Answer by Randy Carey, BOL Guru

Guru Bios

Question:  Are there any violations to FDIC/federal or SEC rules if the bank interfaces the customer information system with their brokerage firm's system to display investment balances, whereby a non-securities licensed employee can see that information and use that information for cross-sell purposes?


Answer:  It is unclear whether the brokerage firm is an affiliate of the bank, so:
  • If you share customer information with your affiliate and your affiliate uses the information for marketing purposes, you have to provide an opt-out under the FCRA.

  • If this is not an affiliate, then you would have to offer an opt-out under the privacy regulations prior to sharing any information with them.


First published on BankersOnline.com 6/22/09







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