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#3092 - 07/20/01 01:42 PM Construction Advertising
KimC Offline
100 Club
Joined: Jul 2001
Posts: 145
Minnesota
Our mortgage broker would like to post signs on home construction sites stating "construction financing by Bank of__". Is this a violation of GLB if our policy is we do not share any information?
Also, we have disclosed our policy to our commercial customers, is this same type of signage a violation for them?

Can we avoid any problem by having the customer sign a release to use the sign?


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General Discussion
#3093 - 07/20/01 02:13 PM Re: Construction Advertising
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
If the construction is a commercial project, no GLB problem. Ask yourself, "Who is the customer?" GLB is a consumer law.

If the construction is an individual project, I can argue both sides. Am I releasing NPPI such as name, address, etc. and the answer is no; however, in a small community, everyone knows who is building which house, but may not know who the lender is until the sign goes up. Seems to be technically ok, but probably goes against the "spirit" of the reg. Anybody else have any thoughts.

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#3094 - 07/20/01 02:58 PM Re: Construction Advertising
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I like to summarize Privacy this way: I can't tell anyone who my customers are." (Yes, I know that there are lots of exceptions - this is a simple summary). By putting a sign in your front yard that basically says "This customer banks with us" I believe you have violated privacy. However, with customer consent, I can share (almost) anything. So why not ask for permission to put the sign in their yard. No problem.
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David Dickinson
http://www.bankerscompliance.com

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#3095 - 07/24/01 12:38 PM Re: Construction Advertising
Anonymous
Unregistered

I would argue that since you are recording a mortgage on the property, the fact that the customer has a loan with your bank is public information.

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