Skip to content
BOL Conferences
Thread Options Tools
#384 - 01/09/01 05:05 AM Privacy / teller systems
Bartman Offline
Diamond Poster
Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
We recently installed a new teller software system. It requires the teller to obtain our customer's account number when cashing not-on-us checks. The software prints the customer's account number on the back of the check 'for identification'.

Since the check will ultimately wind up in the statement of someone at another bank (maybe one of our customers, maybe not), are we violating Reg. P's prohibition against release of account numbers?

Or is this covered under the exceptions?

_________________________
Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

Return to Top
General Discussion
#385 - 01/08/01 10:17 PM Re: Privacy / teller systems
Anonymous
Unregistered

When you allow your customer to cash a check given to the customer by someone whose account is at another bank you are effecting a transaction initiated by the customer. Information disclosed in connection with "effecting, administering, or enforcing" a transaction initiated by the customer is exempt from the opt-out and disclosure provisions.

Honestly, however, I don't think this would even be deemed information "collection" in the pure sense. Either way, the privacy rules should not affect this procedure.


Return to Top