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#2167056 - 03/07/18 06:30 PM Privacy Notice Statement Message
WestKerryGirl Offline
Junior Member
Joined: Dec 2013
Posts: 39
If our privacy notice did not change from last year, if we provide the privacy notice to each new account at opening, and we have a message on our statements pointing to our website to view the notice, do we have to mail that message to each customer who does not receive a statement ie: loans that have coupon books?

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#2167057 - 03/07/18 06:41 PM Re: Privacy Notice Statement Message WestKerryGirl
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Has your notice changed - or do you have to provide opt-outs to customers?
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#2167311 - 03/08/18 09:19 PM Re: Privacy Notice Statement Message WestKerryGirl
WestKerryGirl Offline
Junior Member
Joined: Dec 2013
Posts: 39
We provide Opt outs.

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#2167326 - 03/08/18 09:58 PM Re: Privacy Notice Statement Message WestKerryGirl
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
I would just mail the loan customers with coupon books the privacy notice instead of a message that says look at our website for the notice...
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#2167351 - 03/08/18 11:01 PM Re: Privacy Notice Statement Message WestKerryGirl
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,724
Illinois
If you share information that allows for opt outs the now defunct statement message option is not available to you.
You still must send an annual notice to all customers.
For those who do not share, the statement message option the CFPB made available was not longer relevant when the GLBA was amended to eliminate the annual notice requirement for banks that do not share and have not changed their privacy practices in the last year.
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#2167368 - 03/09/18 12:04 PM Re: Privacy Notice Statement Message BrianC
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Implied: Go back and determine whether your secondary use of customer information produces enough revenue to pay for this completely, totally worthless annual mailing. If not, stop it. Then, send your last annual mailing telling your customers you do not do this anymore.
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#2167430 - 03/09/18 05:07 PM Re: Privacy Notice Statement Message WestKerryGirl
WestKerryGirl Offline
Junior Member
Joined: Dec 2013
Posts: 39
Thank you all. We sent an opt out for state regulations reasons on sharing for a checking rewards program. However the rewards program we instituted does meet the exceptions in 14 in GLBA. Section 14: As necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes, or under certain other circumstances relating to existing relationships with customers. Disclosures under this exception could be in connection with the audit of credit information, administration of a rewards program, or provision of an account statement.

We only provided the original opt out because of state law. Do we still need the full mailing?

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#2167462 - 03/09/18 06:47 PM Re: Privacy Notice Statement Message WestKerryGirl
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
You have to meet State law requirement then.
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