As long as it's experiential (I feel like I'm talking about a hallucinogenic drug) and transactional, you would be OK. However, if it includes disclosing other non-public information, it would trigger the FCRA opt-out notice requirements in order to shield you from being a Credit Reporting Agency.

Now granted, this is a fine line, as most dual employees can't forget what they know just because they are doing one job or the other. But if non-public information from the bank ends up in the brokerage file (for example) and it was not provided to the employee while they were acting in the capacity as employee of the brokerage firm - you could be in for trouble.

I agree with Dan. In the end, all you can do is inform management of the risks associated with certain actions. If they choose to do something against your advice, to have precious few options.

Dan, Randy and Paul -

I totally agree with you, I was just sharing the creative thinking of those outside our wonderful world of compliance. They do keep life interesting!