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Combining the Patriot Act Disclosure with the Privacy Policy Disclosure
Answer from Kent Kluver, Senior Attorney at Bankers Systems, Inc.


Question: Can we combine the Patriot Act Disclosure with our Privacy Policy Disclosure? Our loan officers feel that we already load up our potential loan customers with too much up front paperwork and they want to place both disclosures on one page. Can we do this?

Answer: Neither the Treasury regulation that implements the USA PATRIOT Act nor the financial institution regulatory agency regulations that implement the Gramm-Leach-Bliley privacy law requires that the respective disclosures be separate from other information. So if it is practical for you to combine them, it might be a good idea. Whether it's practical might depend on, for example, whether the same people always get the two disclosures at the same time, or whether combining the disclosures complicates the providing of the customer's means for exercising the right to opt out.

About Bankers Systems
Established in 1952, Bankers Systems, Inc. is a leading national provider of compliance resource solutions for financial institutions and their legal counsel. The company’s deposit, lending, IRA software, documents, disclosures, training, and support services are used by more than 12,000 financial institutions, including 83 percent of banks in the U.S. In addition, over 70 leading core processors and software developers use Bankers Systems’ compliance-related documents and other components in their solutions. For more information, call 800-552-9410.

First published on BankersOnline.com 9/2/03
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