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#1821110 - 06/06/13 05:40 PM Privacy Notice
LAK Offline
Junior Member
Joined: Oct 2012
Posts: 43
Feel rather silly asking, but...1016.3(e)(1) states a consumer is an individual who OBTAINS or HAS OBTAINED a product or service. If the Notice is provided prior to the customer signing deposit or loan documents would this not comply? If denied, it would be disclosed with the denial. It does not have to be specically at time of application? I have seen it both ways.

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#1821114 - 06/06/13 05:45 PM Re: Privacy Notice LAK
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You establish a customer relationship with a consumer when you originate or acquire the servicing rights to a loan to the consumer for personal, family, or household purposes. If you deny the loan, that never happens and no privacy notice is required to be delivered.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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