I have spent so much time reading Regulation P and still am unclear on a few things. We are in the process of acquiring a bank and therefore marrying our privacy disclosure. We have a few inconsistencies and questions based on each of us doing this differently in the past.
When disclosing affiliates, would these apply:
1) Insurance agency
2) Investment department (offers retirement accounts, annuities, ect)
3) Holding company

1016.3(a)(1) Affiliate means any company that controls, is controlled by, or is under common control with another company.

A department is not an affiliate. Your holding company is definitely an affiliate. You would have to know your corporate structure for any other entities.