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#2267509 - 03/11/22 03:37 PM Reg P- 13,14,15
Anonymous
Unregistered

Can someone explain to me, in laymen's terms, what each of the exemption sections of Reg P mean?

Specifically 101613, 1016.14, 1016.15

Thanks,
Eduardo

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#2267512 - 03/11/22 03:53 PM Re: Reg P- 13,14,15 Anonymous
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
The CFPB exam procedures do a decent job breaking down the exceptions into understandable terms:

Exceptions to the opt-out right are detailed in Sections 13, 14, and 15 of the regulation. Financial institutions need not comply with opt-out requirements if they limit disclosure of nonpublic personal information:

Section 13: To a nonaffiliated third party to perform services for the financial institution or to function on its behalf, including marketing the institution’s own products or services or those offered jointly by the institution and another financial institution. The exception is permitted only if the financial institution provides an initial notice of these arrangements and by contract prohibits the third party from disclosing or using the information for other than the specified purposes. However, if the service or function is covered by the exceptions in Section 14 or 15 (discussed below), the financial institution does not have to comply with the disclosure and confidentiality requirements of Section 13.

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.

Section 15: For specified other disclosures that a financial institution normally makes, such as to protect against or prevent actual or potential fraud; to the financial institution’s attorneys, accountants, and auditors; or to comply with applicable legal requirements, such as the disclosure of information to regulators.
_________________________
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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