I wound up coming up with the following for California institutions that don't share in a manner that would trigger an opt-in or opt-out. You can modify as needed.
California law limits an institution from sharing with non-affiliated third parties except as necessary for our everyday business purposes, or to offer our products and services to you, unless you have given us permission.
California law limits an institution from sharing information with affiliates, except as necessary for our everyday business purpose, or to offer our products and services to you, unless we have provided you an opportunity to opt-out of this sharing.
XYZ Bank does not share information with affiliates or non-affiliates for other than our everyday business purposes or to offer our products and services to you.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'