In general, regulation P (and its parallel regulations) apply to every department of the bank; there is no exclusion for the Trust Department. The issue is whether the customer is a consumer. Some of your customers are companies, some are entities (trusts & estates) and some are simply consumers. You must make the same distinctions that the rest of the bank does in determining whether the initial and annual notices are required.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.