This is best asked of counsel, but the RFPA defines a financial institutions as "“financial institution”, except as provided in section 3414 of this title, means any office of a bank, savings bank, card issuer as defined in section 1602 (n) of title 15, industrial loan company, trust company, savings association, building and loan, or homestead association (including cooperative banks), credit union, or consumer finance institution, located in any State or territory of the United States, the District of Columbia, Puerto Rico, Guam, American Samoa, or the Virgin Islands;"
Are you considered a "consumer finance institution?"
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell