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#201195 - 06/17/04 02:26 PM Privacy Disclosures
HR Banker Offline
Diamond Poster
Joined: Oct 2002
Posts: 1,027
Are initial and annual privacy diclosures given to customers of the trust department?

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General Discussion
#201196 - 06/17/04 02:44 PM Re: Privacy Disclosures
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Yes, if they are consumers

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#201197 - 06/17/04 03:03 PM Re: Privacy Disclosures
Anonymous
Unregistered

Whether you have to provide them a privacy notice depends. If you hold a custodial IRA, then the privacy notice applies. Simply being a trust customer does not make them a consumer.

From the regs:


An individual is not a bank's consumer solely because he or she has designated the bank as trustee for a trust.


(vii)
An individual is not a bank's consumer solely because he or she is a beneficiary of a trust for which the bank is a trustee.

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#201198 - 06/17/04 04:56 PM Re: Privacy Disclosures
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Quote:

Simply being a trust customer does not make them a consumer.





Exactly. That's why I put the word "if" in bold.

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