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#1930073 - 06/06/14 12:39 AM CA Privacy Notice - 2nd Set of Eyes, Please!
OceanView Offline
Junior Member
OceanView
Joined: Dec 2013
Posts: 46
San Diego
Holy cow, I'll probably have a fresh take tomorrow morning but any assistance would help below on my understanding of the CA privacy notice.

Issue: If a mortgage lender conducts joint marketing with non-affiliated real estate agents, this would be considered "contracts with outside companies to provide financial products and services." Is this correct?

Following up on the above, the mortgage lender MUST then provide a CA opt-out option to the consumer (so CA is unlike federal GLB. Because GLB provides an opt-out "exception" for joint marketing purposes under section 13.)

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#1930322 - 06/06/14 04:37 PM Re: CA Privacy Notice - 2nd Set of Eyes, Please! OceanView
ItNeverEnds CRCM Offline
Platinum Poster
Joined: Oct 2006
Posts: 995
Looking for my sanity
I'll take a stab here, with the caveat that we don't share under this reason. But my understanding is that in the case you describe above, under CA SB1, you would need an Opt In. You can only share in a financial joint marketing arrangement with non-affiliated third parties under an "Opt Out" if the other party is a financial institution. If the other pary is not a financial institution, then you actually need an Opt In.

Maybe someone else who shares under CA law can opine here.
_________________________
"The reason I talk to myself is because I'm the only one whose answers I accept."
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