I've searched for an answer to this question, but have been unable to find one. We are mailing out our annual privacy notices. Do we need to send one to guarantors of consumer loans?

I was unable to find anything regarding guarantors. However from a logical thought process, I would disclose the privacy policy because you must have obtained personal information on the guarantors when making the loan. Otherwise, why have them as guarantors. I would send it out to them as well.

REGULATORY GUIDANCE: Qs/As from the Regulators on Privacy Regulation

B.3. Q. Is a guarantor or an endorser of a consumer loan considered my consumer or customer?
A. A guarantor or endorser of a consumer loan is your customer because the individual assumes secondary liability on the loan he or she guarantees or endorses and thereby receives an extension of credit from you. You may, however, treat the primary borrower and the guarantor or endorser as joint account holders. As a result, you may deliver a single privacy notice to the joint account holders in accordance with § 332.9 <../../../../regulations/laws/rules/2000-5550.html>(g). If you disclose information to nonaffiliated third parties outside of the exceptions in §§ 332.13 - 332.15, you must also provide the primary borrower and the guarantor/endorser with an opportunity to opt out. You may deliver a single opt out notice to the joint account holders under § 332.7 <../../../../regulations/laws/rules/2000-5550.html