I suspect I've thought myself into a box here...
Reg. P allows for joint marketing agreements, and proper disclosure under section 13 allows me to share info without Reg. P opt-out.
FCRA section 603(d)(2) talks about sharing transaction & experience information with entities under common ownership & control as allowable without FCRA opt-out, and sharing anything more with entities under common ownership & control as allowable WITH FCRA opt-out.
But what may we share with entities NOT under common ownership?
We have an agreement with a local trust company to provide investment services. We don't have an ownership interest. I think joint marketing language in the privacy notice will fall under Reg. P section 13 and allow us to avoid opt-out, but I don't see the FCRA exemption.
Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."