We sold a consumer loan to an affiliate bank. Our Privacy Policy indicates we share NPI with affiliates. The decision to sell the loan was made after closing. We retain the servicing. We provided a copy of the credit report to our affiliate with the rest of the file documentation.In my research I don't believe we have a Privacy issue, but do we have a FCRA issue for not providing the consumer with the opportunity to opt out of this information sharing? Thanks in advance for any help.

No. This is one of those situations where the business transaction overrides any privacy. When you sell the loan, the purchaser has a right to see the entire file. The credit report goes with that.

Thank you very much.