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#398006 - 08/08/05 02:02 PM trust dept and privacy
Anonymous
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We have a trust office within our banking company. The trust office is located in a different office than our bank and branches. Does the trust department have to provide Initial or Annual Privacy Policy notices under Reg P?

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Operations Compliance
#398007 - 08/08/05 02:14 PM Re: trust dept and privacy
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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