I am doing a review of abandoned property (New York) right now. One thing that is required is to advertise in the local newspaper 30 days after the preliminary report filing is the names and last known addresses of persons appearing to be entitled to property of $50 or more.

Is this a violation of Reg. P? I am also going to post my question in the NY forum. I would think that it would be a violation.....

Look toward 216.15(7)(i):

"To comply with Federal, State, or local laws, rules and other applicable legal requirements"

Regulation P and its parallel regulations are not a source of authority for making a disclosure. Nor are they a source of authority for prohibiting a disclosure other than an account number. All the regulation requires is that financial institutions give consumers disclosures of their practices and, if they make disclosures other than those “allowed by law” they must give the consumer a chance to opt out. This is simply not a disclosure the consumer has a right to opt out of.