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#2025939 - 07/08/15 05:07 PM GLBA compliance Audit
Combustible Offline
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Joined: Dec 2008
Posts: 1,268
Internal Auditor starting a GLBA compliance audit and trying to figure out how I can prove the bank is compliant with the disclosure being provided. It says "We don't share for joint marketing with other financial companies", Any help will be appreciated.

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Audit
#2025948 - 07/08/15 05:27 PM Re: GLBA compliance Audit Combustible
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
OK - the GLBA is a huge Act and covers any number of a hundred things. I take it you are talking specifically about a review of your privacy disclosure??

Proving a negative is virtually impossible. You tell them you don't have any joint marketing agreements, you give them access to all of your vendor and other agreements, you give them access to all product offerings and tell them to find something that says you do.
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#2025976 - 07/08/15 06:11 PM Re: GLBA compliance Audit rlcarey
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Trying not to just restate the above, but....

This is an Internal Auditor, so should be easy. That person is in the bank watching the marketing go by. When I do this audit, I do exactly what was stated above, I look at the marketing materials for the last year, any contracts, and then I just have a conversation with our head of marketing and our head lender ... Are we collaborating with anyone else or providing customer lists to anyone else that I don't know about?

It's almost more clear to get together a list of those with whom we DO share .... like credit bureau companies, etc....and then hold that "sharing" up to the boxes checked on the privacy notice. The notice is either correct or not.

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#2026134 - 07/09/15 11:53 AM Re: GLBA compliance Audit Combustible
Combustible Offline
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Joined: Dec 2008
Posts: 1,268
yes, thank you so much. Turtle, you are an auditor too?

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#2026179 - 07/09/15 02:37 PM Re: GLBA compliance Audit Combustible
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Yup! I do our internal audit, our regulatory compliance audit, the QC and the BSA audit.

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