I have searched and can't find my exact question posed, so here goes:
We offer investment services through a third party (with a dual employee (investment rep) employed by us and the third party). The Investment Rep would like us to send out a seminar invitation to certain bank clients (i.e. 50+ account holders) on his behalf. Our Privacy Policy states that we do not share unless for loan servicing, etc. and offers no opt out. We would not be sharing the names or any information with the rep, just mailing out the invitations.
Is this ok, as long as we don't provide the rep with any names or account information?
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I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!
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