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#1466668 - 11/10/10 06:50 PM Model Privacy Notice
Dallas Fan Offline
100 Club
Joined: Feb 2008
Posts: 219
RIC
I am completing the Model Privacy Notice using the new form builder and I have a couple of questions. The Credit Union I work for has several affiliated companies (CUSOs) that we use to provide mortgage service, title service, etc. We don't share information with the affiliates so they can market to our members. However, on occasion, we will send out a marketing piece which promotes/mentions the affiliate to our members and has the both the CU logo and the affiliate logo on the piece. We do not intend to provide an opt out as the only time information is shared is when someone "requests" a service. Am I interpreting the Reg correctly?

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General Discussion
#1466678 - 11/10/10 07:01 PM Re: Model Privacy Notice Dallas Fan
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
Yes. Sharing information in order to complete a transaction or provide a requested service is covered in the 216.14 exceptions.
_________________________
I've just writed a wrong.

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#1467012 - 11/11/10 06:19 PM Re: Model Privacy Notice GuitarDude
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,337
Wisconsin
Does one consider a bank holding company an affiliate in determining which privacy notice to use?

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#1467026 - 11/11/10 07:35 PM Re: Model Privacy Notice CSB98
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
A BHC would be considered an affiliate, which is defined as any company that controls, is controlled by, or is under common control with another company.

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