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#2226243 - 11/24/19 11:38 PM Sharing with Affiliates
2old2care Offline
Platinum Poster
Joined: Oct 2006
Posts: 710
PA
Currently, our Privacy Notice states:

For our affiliates everyday business purposes - information about your transaction and experiences: YES we share - No You cannot limit.

We have an investment firm as the banks affiliate. We have never shared information but would like to going forward. Since this is "transaction" experiences, I take it we could share all the customers information, including account numbers, on all transactional accounts. Is this correct?

The next check box on the privacy notice is:
"For our affiliates everyday business purposes - Information about your creditworthiness." NO we do not share


If we change the second statement to "yes," send out new privacy notices so customers can opt out, can we then share all credit information (except the credit report) with our affiliate?

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#2226245 - 11/25/19 10:05 AM Re: Sharing with Affiliates 2old2care
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,336
Galveston, TX
What is your affiliate going to do with this information once they have it?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2226263 - 11/25/19 04:48 PM Re: Sharing with Affiliates 2old2care
2old2care Offline
Platinum Poster
Joined: Oct 2006
Posts: 710
PA
The Investment Company will use the information for mailings and phone solicitations. I know our Privacy Notice will have to be updated and mailed to our customers. Thirty days after the mailing, The Investment Company will begin sending marketing materials and making phone calls to any customer who has not opted out.

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#2228785 - 01/10/20 07:29 PM Re: Sharing with Affiliates 2old2care
deltacrcm Offline
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Joined: Apr 2015
Posts: 220
Reviving this topic, if you send the customer a new privacy policy and alert them to the opt-out option, but you do not receive a response from the customer, do you assume they are opted out or can we assume they are opted in and begin sharing?

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#2228792 - 01/10/20 07:47 PM Re: Sharing with Affiliates 2old2care
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,336
Galveston, TX
Sec. 624. Affiliate sharing

(a) Special Rule for Solicitation for Purposes of Marketing

(1) Notice. Any person that receives from another person related to it by common ownership or affiliated by corporate control a communication of information that would be a consumer report, but for clauses (i), (ii), and (iii) of section 603(d)(2)(A), may not use the information to make a solicitation for marketing purposes to a consumer about its products or services, unless--

(A) it is clearly and conspicuously disclosed to the consumer that the information may be communicated among such persons for purposes of making such solicitations to the consumer; and

(B) the consumer is provided an opportunity and a simple method to prohibit the making of such solicitations to the consumer by such person.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2228797 - 01/10/20 08:03 PM Re: Sharing with Affiliates 2old2care
deltacrcm Offline
100 Club
Joined: Apr 2015
Posts: 220
I read that to say if they are 'provided an opportunity' (30 days from provision of the revised privacy notice with opt-out information), but do not respond instructing us not to share, then we can assume they are 'opted in'.

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#2228802 - 01/10/20 08:21 PM Re: Sharing with Affiliates deltacrcm
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 315
USA
I agree with you that if they are given the opportunity to opt out but do not do so, you can consider them opted in.
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