our home loan dept wants to share some information with non-affiliates.on home loan customers.
So we need to change our current "we do not share" notice to one that gives customers the right to opt out.
My question is do we have to have the same privacy policy for the rest of the bank - i.e. deposts - we still do not share.
what I see happening is we revise the notice and all of a sudden a lot of deposit customers are calling in to opt out where they were not the ones we were going to share on.

A bank has one privacy policy. It's nice that the home loan department wants to do that, however what is really in it for the bank? What non-affiliates and what other compliance issue might this present?

Calculate the cost of sending a notice to all existing customers, sending annual mailings to the same group thereafter, and running an opt out program. Tell the folks in the "home loan department" that amount will be charged to their cost center...

Randy


our real estate department is looking at the ability in our online application process to allow customers to get a quote from an insurance company where we would send the customer info to the insurance company.

And the projected income from that act compared to the costs that Ken outlined is what? Since "Provision of services involving hazard, flood, or other casualty insurance or homeowner's warranties" are defined as a settlement service in 1024.2 and the payment of such a referral would be a Section 8 violation?

12 U.S. Code § 2607 - Prohibition against kickbacks and unearned fees

(a) Business referrals

No person shall give and no person shall accept any fee, kickback, or thing of value pursuant to any agreement or understanding, oral or otherwise, that business incident to or a part of a real estate settlement service involving a federally related mortgage loan shall be referred to any person.