Are mortgage loan terms considered non-public personal financial information under Regulation P? The relationship between the lender and the consumer would be public information in the mortgage DOT but would sharing the loan terms along with the customer name be an issue? (When I say loan terms I am referring to rate/product type/term of the loan. I am thinking it might fall under (ii) below but would like an additional perspective.

Personally identifiable financial information means any information:

(i) A consumer provides to you to obtain a financial product or service from you;

(ii) About a consumer resulting from any transaction involving a financial product or service between you and a consumer; or

(iii) You otherwise obtain about a consumer in connection with providing a financial product or service to that consumer.

1016.14(b) Necessary to effect, administer, or enforce a transaction means that the disclosure is:

(1) Required, or is one of the lawful or appropriate methods, to enforce your rights or the rights of other persons engaged in carrying out the financial transaction or providing the product or service;

Sorry, my reference to the recording was just to mention that the relationship between lender and consumer was public information. To clarify, this information is being provided to an unaffiliated third-party for that third-parties use in marketing. Wondering if the consumer's loan terms would be an issue to share without the opt-out.

You providing it to a third party? That would require an opt-out.

Thank you.