We have a newly formed "dual employee" non deposit investment program in which the lead sales representative would like to contact former customers (from an institution in which the individual was employed) indicating his new employment with us. Is this permissible under the Privacy Regulations? I would think there could be an issue with non public personal information. The same scenario could be applied to the real estate or insurance field where a rep transfers to a competitor and contacts their former customers regarding their new employer.

Make sure they didn't sign a "will not compete" sort of a clause in their employment contract. I am sorry I don't know about the rest. I would think it would be a breach in that the employee is telling all of you that those customers have accounts at his place of old employment.

I'm reluctant to offer any reply at all to someone with such a horrible username (I'm a diehard Duke fan and charter member of the ABC club), but guess I'll lower myself.

It really depends, I think, on where the person got the contact information and what additional information he/she has and whether they have a right to that information. If they took proprietary financial information from their former employer, then I'd have a serious issue about using that information. (I'd also have serious issues about the integrity of that employee and would be wondering what information of mine they'll take to their next employer). But if they've got names and phone numbers and just using their memory of what transactions they dealt with, that wouldn't necessarily violate any privacy regs. Now if they are calling these individuals, you would have to screen against the national "Do Not Call" list and any state list. The fact that the rep had a prior business relationship does not carry over to the new employer.

Hope this helps.

Thanks for the replies. They were very helpful and only solidified what we had thought. Thanks again. Go HEELS!

And who won the ACC tournament