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#456938 - 11/15/05 04:41 PM Privacy Notice on website
Gina Z Offline
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Joined: Nov 2005
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Does the same privacy notice that is sent annually to customers also need to be posted on a bank's website?
Does the privacy notice need to be posted on the website and require the consumer to acknowledge receipt of the notice as a necessary step to applying for a home equity loan, HELOC, personal loan?

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eBanking / Technology
#456939 - 11/15/05 08:48 PM Re: Privacy Notice on website
RR Joker Offline
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1- yes
2- It can be done this way...or if the application is just available for the consumer to print and then bring in to the loan office, it could be done at that time, or by closing.

I'd have to go back and look, but if memory serves me it will depend on your particular policy of sharing information and whether it involves all consumers or only customers. If the later, then I'm thinking it's not required until that customer relationship is actually established. In other words, if the loan is declined, the may never be a customer, just a consumer.

Oh boy..I need to go back and read ours...we don't share, so we fall in the later group, but I need a refresher. It's funny..seems like once you establish procedures, you kinda get lax on the fine points until you go back to review again!

I went back and looked and will stand by the above statement!
Last edited by joker; 11/15/05 08:57 PM.
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#456940 - 11/16/05 01:36 AM Re: Privacy Notice on website
Andy_Z Offline
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I'll disagree on 1. The policy only needs to be there if that is your means of delivery. If you are opening accounts there, really opening the account, or referring customers to the page for the annual disclosure. If they haven't consented to receiving it this way, they need it delivered via some other means.

It isn't required to be on your site. I do encourage it! But unless you are doing business so that this is the means of delivery, it need not be there.
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AndyZ CRCM
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#456941 - 11/16/05 02:35 PM Re: Privacy Notice on website
RR Joker Offline
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RR Joker
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Thanks for the specifics, Andy. We do disclose ours and have conformed it to the same as our delivered notice, per regulator recommendation. (it used to be much more entailed and have to do more with website features and data collection than it did just the regular notice)...I guess we do it as a "public service" or "goodwill" so-to-speak, so that a potential customer will know our stance.
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#456942 - 11/16/05 06:12 PM Re: Privacy Notice on website
Andy_Z Offline
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To me, it makes sense to operate your website as a branch, and that includes signage. These are easy to post items. They demonstrate your desire to inform customers or what you do and it is a low maintenance issue. I'd post privacy, HMDA, annual disclosure, fair housing, etc.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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