Sending Financial Information Over Non-secure Line Trent Fleming and Richard Insley, BOL Gurus Guru Bios
Question: In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
Answer by Trent Fleming: Although I can't give you true legal guidance, I would offer that you are correct - the recent OCC case in Colorado, involving bank employees sending customer information via non-secure email seems to confirm your suspicion.
Answer by Richard Insley: It's at least a security problem, if not privacy. No one intends for messages to be intercepted and read by unauthorized parties, so it's not quite the same level of concern as delivery of privileged info to unauthorized parties.
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