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#2019100 - 06/08/15 07:14 PM vendor providing escrow acct service-? privacy
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
We have recently established a relationship with another bank to provide the servicing for our home mortgages with escrow accounts- they have thousands of accounts on the books and we have less than 50 at this time.

My question has to do with the privacy notice we provide currently we do not share any information and as such do not provide the opt-out language in our disclosure - my thoughts are that this type of service still falls under the exemption #14 because they are using the non-public information they have to provide an account statement. Is this correct? I would appreciate any thoughts on this matter.

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Lending Compliance
#2019872 - 06/11/15 04:32 PM Re: vendor providing escrow acct service-? privacy Chocaholic
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 958
Lost in a regulatory fog
Correct. You are sharing this information to complete a transaction. The customer does not have the ability to opt-out of that sharing.

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