Our bank owns a mortgage company. We want one of the loan processors for the mort. co. to process some of the bank's loans for 60 days. In our privacy notice, the portion about sharing with affiliates indicates we share only our own experiences - therefore we do not offer an opt out. By allowing the mort. co. person to order VOE, VOD, and other paperwork, does this go against what we describe in our privacy notice or is it totally unrelated? I'm confused

You are temporarily shifting an employee. I don't see that as a privacy change as the mortgage group is not going to be using this information.

Do we need to make any disclosures at all then to the consumers about a mortgage employee will be the person gathering all the information for making the loan? Any opt-outs or anything? I really appreciate your input Andy!

I don't think so. This is a temporary employment type issue, not one of sharing information. The employee is not expected to go back and cross-sell to apps she worked on at the bank. The employee is putting on a different hat at that point.

Ok - last question - I hope! What if this mort. co. employee pulls credit or see a credit report with information on the customer that is not bank information. Then, are we sharing other information (not our own experiences)and need an opt out?

The employee is not taking back the information or using it in any way for the mortgage dept. The information isn't shared. You could have a confidentiality agreement signed if you wanted.