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#2211933 - 04/24/19 01:50 PM Privacy Disclosure vs. Privacy Notice
Brightside3277 Offline
Member
Joined: Aug 2012
Posts: 88
Oklahoma
One of our operations personnel has brought up which terminology is correct when explaining the Privacy Notice/Disclosure to the customer. I did some research and came up empty handed, and I don't remember this being discussed in Compliance School. Is anyone familiar with this?
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Keep calm, and let the compliance officer handle it....

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General Discussion
#2211935 - 04/24/19 01:57 PM Re: Privacy Disclosure vs. Privacy Notice Brightside3277
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
I am failing to understand your question. What are you explaining to the customer?
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#2211937 - 04/24/19 02:04 PM Re: Privacy Disclosure vs. Privacy Notice Brightside3277
Brightside3277 Offline
Member
Joined: Aug 2012
Posts: 88
Oklahoma
What she is saying is that she was told not to say "Privacy Notice" when explaining the "Privacy Disclosure" to the customer when they open a new account. I realize this is splitting hairs, and I would agree. However, she is adamant that the prior Compliance Officer told her to never say "Privacy Notice," and I am wondering if maybe I missed something. In one of our new account brochures we refer to the Reg P disclosure as a "Privacy Notice" and this is how the question came about.
Last edited by Brightside3277; 04/24/19 02:09 PM. Reason: Additonal Information
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Keep calm, and let the compliance officer handle it....

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#2211939 - 04/24/19 02:18 PM Re: Privacy Disclosure vs. Privacy Notice Brightside3277
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
Subpart A—Privacy and Opt Out Notices

Sec. 1016.4 Initial privacy notice to consumers required.

Since the CFPB calls it a Privacy Notice, why can't you?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2211951 - 04/24/19 02:46 PM Re: Privacy Disclosure vs. Privacy Notice Brightside3277
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
I agree with Randy and have never seen issues in what the disclosure/notice is verbally called - you just need to be sure you deliver it.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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