the time the client established a relationship with the Bank?
The FRB last week allowed FRB banks to no longer send an annual privacy Notice if nothing has changed. This is reportedly an interagency exam revision but it is not in the OCC or FDIC data and it only addresses Reg P which the FDIC does not follow. Questions - Are FDIC and OCC banks now exempt from sending an annual Privacy Notice if they are not subject to have to send the notice referenced in the FRB Memo. I cannot find anywhere that the FDIC and OCC have adopted the procedures.
I am currently working on an audit for the RFPA. We have several verification of deposit that come into our bank from state and local government agencies. For example, the local housing authority sends requests pertaining to the Federal Assisted Housing Program. Should we treat these requests as if they came from a federal agency and should they contain the RFPA disclosure?
What is required or what is the best liability protection when allowing a non-owner to obtain account information?
We currently have a vendor for our credit card product distributing privacy notices that are dated for the year 2012. While we are using the model form with accurate information, and our clients are receiving a privacy notice, I am concerned about the date of 2012 and if we are in violation or could face potential fines?