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#1915682 - 04/18/14 02:25 PM Privacy and an IPO
YHWB Offline
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Joined: Apr 2005
Posts: 607
Out there
Currently, our Bank states that we do not share information with affiliates for marketing purposes. Our annual notice lists the the bank and the holding company. Should the bank wish to share client information (names and addresses) with the holding company in the future for an IPO solicitation, would the bank need to modify its privacy notices, re-issue those to all clients, and develop an opt-out process for clients to use? What would be the waiting period between the change in notice, and the ability to share the infromation?

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General Discussion
#1915733 - 04/18/14 03:11 PM Re: Privacy and an IPO YHWB
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,660
Galveston, TX
I would be more concerned with SEC laws and regulations.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1915741 - 04/18/14 03:17 PM Re: Privacy and an IPO YHWB
YHWB Offline
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Joined: Apr 2005
Posts: 607
Out there
Since we have others looking into that, I was trying to get confortable with this issue.

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#1915758 - 04/18/14 03:31 PM Re: Privacy and an IPO YHWB
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,660
Galveston, TX
would the bank need to modify its privacy notices, re-issue those to all clients, and develop an opt-out process for clients to use?

IMHO - yes
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1916298 - 04/21/14 08:40 PM Re: Privacy and an IPO YHWB
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
As far as your question about the waiting period, 12 CFR 1016.10(a)(3) indicates that 30 days from the date of mailing must be given before sharing.

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#1916676 - 04/23/14 01:02 PM Re: Privacy and an IPO YHWB
YHWB Offline
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Joined: Apr 2005
Posts: 607
Out there
Thanks Ted.

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