Our insurance affiliate (subsidiary of the bank)wants our real estate department to provide the names and addresses along with insurance expiration dates to them to solicit business. I say that that is more than transactional experience and would need an opt-out. Could we have the customer sign a release form when they close the loan saying that they would like a quote from the insurance company? We already have it stated in our privacy notice that we may share with our affiliated insurance company. Any comments?

Revised regs. in proposal state that you must have an opt-out option for affiliates. I would go "better safe than sorry" on this one and disclose with an opt-out option. CA laws already require this and it looks like federal laws will follow suit soon.