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?

Not unless it says something like "If we ever share, here are the rules".