I am wondering if anyone provides potential borrowers, that have been denined for loan, a copy of the banks privacy notice? I know they are suppose to be for customers, but since we have the credit report and application with NPI on it, should we be giving them one?

Thank you in advance for your input!

I do not believe a privacy notice is required in this case. You never established a customer relationship with the potential borrower. The information you used to evaluate the loan, and anyone you shared it with (credit bureau for credit report, etc.) falls under the exceptions at 1016.14:
(a) Exceptions for processing transactions at consumer's request. The requirements for initial notice in §1016.4(a)(2), for the opt out in §§1016.7 and 1016.10, and for service providers and joint marketing in §1016.13 do not apply if you disclose nonpublic personal information as necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes.

Thank you backstreets. I did not think we had to, but sometimes I read too much into the Regulation and get myself confused!

Thank you again!