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#204448 - 06/25/04 01:00 PM FACT Act Notice of Negative Information Customer?
Anonymous
Unregistered

Has it given anyone else heartburn that section 217 indicates that the notice goes to a "customer" and "customer" has the same meaning as in Gramm Leach Bliley (GLB) and GLB does not define customer? GLB defines customer relationship, but not customer. The regs implementing GLB define customer. And this would not include guarantors and the like. It is easy to get tangled up in the FCRA web.

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#204449 - 06/26/04 04:05 PM Re: FACT Act Notice of Negative Information Customer?
Bear Collector, CRCM Offline
Diamond Poster
Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
Reg P does define customer - Customer means a consumer who has a customer relationship with you. Because Reg P implements the Privacy provisons of GLB, I am assuming that this is the definition we should rely upon.
BC
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