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Question & Answer

Question: Can we share bank customer information with the third party vendor?

Answer: Sharing customer information with a third party vendor - or even using it for direct bank programs - is something that strikes icicles of fear into the hearts of broker/dealers - at least those that are not affiliated with banks! The broker/dealer industry strongly opposes letting banks use customer information to support the sales program.

However, the federal bank regulatory agencies see this problem differently. They say yes - sharing certain customer information is permissible to support the program. For example, the agencies believe that it would be appropriate to share information on certificates of deposit scheduled to mature.

Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 16 & 17, 12/97

First published on 12/01/1997

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