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#1957771 - 08/28/14 03:34 PM Privacy
amberleigh Offline
Junior Member
Joined: May 2011
Posts: 34
Our privacy disclosure we provide to customers states that we do NOT share any non-public information with affiliates nor do we share creditworthiness informatoin with our affiliates. Therefore, we do not provide an opt-out notice to our customers. (there is nothing that we share that they can opt out of). However, in our bank's Privacy Policy that goes to the board for approval, there is a big section concerning Opt-out. Is that even needed in the actual board policy since we don't share any information that a custmer would have the ability to opt out of?

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Operations Compliance
#1957781 - 08/28/14 03:40 PM Re: Privacy amberleigh
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Not unless it says something like "If we ever share, here are the rules".
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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