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#1400414 - 06/07/10 09:47 PM Documents sent to wrong e-mail address
Pamlissa Offline
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Rosemont, IL
One of our loan officers sent a loan client's documents, including a fully filled-out 1003, to the wrong e-mail address. As soon as our LO realized it, the client, who was more than understanding, was contacted. I advised the client to keep a close eye on their credit report over the next 12 months for suspicious activity, and to place a fraud alert on her credit. We are opening an incident report to document the situation. The client does not want to pursue any claim against us as there has been no harm done at this point. Does anyone have any further suggestions as to how to handle this situation going forward, or further advice I might offer to the client?

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#1400463 - 06/08/10 04:41 AM Re: Documents sent to wrong e-mail address Pamlissa
rlcarey Offline
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Galveston, TX
How about reviewing bank policy concerning the delivery of sensitive customer information outside of a secure environment??? This is not a one time "oops" issue if the bank routinely delivers documents in this manner. Even with the right e-mail address, documents delivers without proper security does not mean that they are not blasting this information into the ionosphere.
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#1401038 - 06/09/10 02:56 AM Re: Documents sent to wrong e-mail address rlcarey
wavewatcher Offline
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Hawaii
this email was sent out unencrypted? i used to run a review with the CIO for departments (loan, HR, and marketing were notorious) to see what types of emails they sent out unencrypted. followed up with a report to the supervisors and a report to the audit committee with dept's responses.

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#1401347 - 06/09/10 05:23 PM Re: Documents sent to wrong e-mail address wavewatcher
Pup Offline
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Is there not a liability placed on the bank to pay for credit monitoring in a "breach" of personal information?

Also, ditto rlcarey and wavewatcher.

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#1401415 - 06/09/10 06:20 PM Re: Documents sent to wrong e-mail address Pup
Pamlissa Offline
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Joined: Oct 2009
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Rosemont, IL
Q: How about reviewing bank policy concerning the delivery of sensitive customer information outside of a secure environment???
A: We have no policy that addresses this. Would you be willing to send me a sample of yours?
Q: followed up with a report to the supervisors and a report to the audit committee with dept's responses
A: The supervisors already know about it, and we do not have an audit committee.
Q:Is there not a liability placed on the bank to pay for credit monitoring in a "breach" of personal information?
A: I'd really like to know the answer to this one - to me it seems like it is the least we could do. I know right now the customer is paying to monitor her credit for the next 12 months, which I think sounds very unfair. Does anyone know if this is something that we are obligated to pay for?

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#1401512 - 06/09/10 07:55 PM Re: Documents sent to wrong e-mail address Pamlissa
BrendaC Offline
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Sweet Home AL
I would implement process to encrypt any email containing sensitive information. I would also offer to pay for a credit monitoring program for at least one year for this client. Just because they are OK now, doesn't mean that they'll continue to be OK if something negative (such as ID theft) happens.
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#1401792 - 06/10/10 02:56 PM Re: Documents sent to wrong e-mail address BrendaC
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I thought you weren't allowed to send out loan documents without using E-Sign? RESPA speaks to this requirement in the 4/10 FAQs.

E-Sign requires borrowers consent and then use of a password to get at the secured docs online plus various other precautions.

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#1401800 - 06/10/10 03:03 PM Re: Documents sent to wrong e-mail address Truffle Royale
Pamlissa Offline
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Rosemont, IL
Did I miss the most recent update of FAQs? I have the copy for 4/2 update. Is there on for 4/10 after that?

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#1401845 - 06/10/10 03:35 PM Re: Documents sent to wrong e-mail address Pamlissa
Truffle Royale Offline

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4/10 = April, 2010. p.3 3) speaks to the requirement to follow E-Sign if you're going to email a borrower.

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#1401846 - 06/10/10 03:35 PM Re: Documents sent to wrong e-mail address Truffle Royale
Pamlissa Offline
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Rosemont, IL
Oh, ok, thank you!

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#1408213 - 06/25/10 03:15 PM Re: Documents sent to wrong e-mail address Pamlissa
DEL Offline
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Joined: Oct 2002
Posts: 730
Maine
There is no requirement to provide credit monitoring to a customer who's information has been compromised, but we routinely do it - it's not very expensive and really helps create goodwill with the customer. We find less than 30% typically end up actually signing up for it.

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#1409950 - 06/30/10 03:51 PM Re: Documents sent to wrong e-mail address DEL
West Coast Comp Offline
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Lost in the rain.
I'm with DEL. It's not required but it sure makes the customer much happier when it is offered.
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#1410303 - 06/30/10 07:30 PM Re: Documents sent to wrong e-mail address Pamlissa
Fraudman CFCI Offline
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Land of Steady Habits
Seems to the least your bank should do is pay for the customer's monitoring.

Seems also someone should learn to encrypt sensitive e-mail!

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