Disposal of Consumer Information

Question: In light of the final rule on proper disposal of consumer information, is there more that financial institutions need to do? In other words, does this require more than G-L-B information security and privacy?

Answer: As a practical matter, if your institution has done an effective job at designing and maintaining an information security program, you may be most of the way home - if not all of the way. The critical issues are information security and disposal of information - particularly those old denied loan applications. That being said, this is not a time to rely on assumptions. It is most definitely the time to take assessments of where the consumer report information exists and whether it is always adequately secure.

Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 15, 12/04