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#1525763 - 03/23/11 02:53 PM Annual privacy notice
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
I just started a Privacy compliance audit and was wondering, does a bank also have to send the annual notice to those customers who only have loans or CD accts but do not have checking or savings accounts. If that statement makes sense...I think we're only mailing to our checking account customers?

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Operations Compliance
#1525774 - 03/23/11 03:06 PM Re: Annual privacy notice Southern gal
Y'all Comply Offline
100 Club
Y'all Comply
Joined: Aug 2010
Posts: 214
Land of Pears
You should be mailing to all customers, not just those with checking accounts.
_________________________
CRCM, CAMS - Be Grateful!!

FKA Jenabq

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#1525777 - 03/23/11 03:10 PM Re: Annual privacy notice Y'all Comply
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Right. It goes to all CUSTOMERS, anyone with an ongoing relationship with the bank, not just deposit customers.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1525815 - 03/23/11 03:51 PM Re: Annual privacy notice Kathleen O. Blanchard
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
Thanks guys...

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#1525873 - 03/23/11 04:46 PM Re: Annual privacy notice Southern gal
Bob The Banker Offline
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Bob The Banker
Joined: May 2010
Posts: 958
You should review Reg P, specifically special rules for loans. Consumers can become your Customers under the special rules for loans.

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