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#32879 - 09/16/02 04:06 PM Privacy - affiliates
SteveG Offline
Member
Joined: Jul 2001
Posts: 58
Can you share (under the .15 exception perhaps?) w/an affiliate the existence of/details of a SAR ... you don't know if the customer is also a customer of the affiliate. Thanks.

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#32880 - 09/16/02 05:37 PM Re: Privacy - affiliates
RVFlyboy Online
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RVFlyboy
Joined: Oct 2000
Posts: 5,984
Soaring over Georgia
Interesting question. I do know this much - section .15 will have no bearing on this at all. Why? Because all of the privacy reg, including section .15 only deals with non-affiliate sharing - there is nothing there restricting affiliate sharing at all. The place where affiliate sharing is restricted is in the Fair Credit Reporting Act. And there, it's only restricted to the extent the information being shared is considered "consumer report" information. So the existence of a SAR wouldn't necessarily be a consumer report piece of information, but there are additional questions raised about the confidentiality of a SAR filing which for the most part prohibit disclosure to the person on whom the SAR was filed. I don't have the SAR regs handy to go back and see if there is any restrictions on confidentiality with other parties or not - as I said this is the interesting part of this question. My initial reaction would be that it would be OK to share this information with an affiliate, but I'm open to other opinions on this too.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
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