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#1883512 - 01/06/14 08:50 PM Privacy Notice and Other Notices
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
A question was asked of me that our bank is going to send out its annual privacy notice which will include all products including loans. Can we send out other notices such as new fee disclosures in the same mail out or does the privacy notice have to be send separately.

Thanks

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Operations Compliance
#1883518 - 01/06/14 08:57 PM Re: Privacy Notice and Other Notices CrashDavis
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 485
Knee Deep in Regs
We send our privacy notices separately, but I have received privacy notices from other sources included with other documents like statements, etc...
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#1883605 - 01/07/14 03:22 AM Re: Privacy Notice and Other Notices CrashDavis
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
Originally Posted By: CrashDavis
A question was asked of me that our bank is going to send out its annual privacy notice which will include all products including loans. Can we send out other notices such as new fee disclosures in the same mail out or does the privacy notice have to be send separately.

Thanks


The 2001 Interagency Privacy faqs state that the privacy notice can be combined with other information but must be clear and conspicuous.

http://www.federalreserve.gov/boarddocs/press/general/2001/200112122/attachment.pdf
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#1883662 - 01/07/14 02:35 PM Re: Privacy Notice and Other Notices CrashDavis
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
Thanks

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#1883679 - 01/07/14 03:00 PM Re: Privacy Notice and Other Notices CrashDavis
CSThompson Offline
Junior Member
Joined: Feb 2009
Posts: 33
Ohio
Did the legislation pass at the end of 2013 doing away with the annual privacy notice mailing unless there were changes made to your privacy notice?

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#1883692 - 01/07/14 03:12 PM Re: Privacy Notice and Other Notices CrashDavis
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
The annual notice has not been eliminated at this point.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1884518 - 01/09/14 03:09 PM Re: Privacy Notice and Other Notices CrashDavis
Milby Offline
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Joined: Apr 2007
Posts: 953
Tejas
For what it is worth, I found that mailing privacy notices separately was cheaper than stuffing into statements, then locating loan-only, CD-only, dormant-only, and other account holders that are not getting a regular monthly statement and mailing them a separate notice. It was (after taking my peoples' time into account) less expensive and less of a headache to do it separately. The regulators also liked it because I would just say "we mailed to everyone on this day" rather than having to provide details on the statement cycles and afore-mentioned loan/CD/dormant clients.

I figure the big banks came to that same conclusion - Chase, Wells, and Citi all send me my privacy notice in a separate mailing.

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