Our privacy policy does not allow sharing of information with third parties. We would like to co-share advertising with vendors (appliances, home furniture, pest control treatments, air conditioners, aluminum storm shutters, etc.) and provide discount coupons from these vendors for all new mortgages closed.

What disclosures, if any, would be required to customers upon closing? Would we need to redisclose a new privacy policy that indicates this marketing plan to all our customers?

If you are just providing your customers with the coupons and not giving the vendors any information on who you are giving them to, there is no issue.

If you are providing info to the vendors (which will undoubtedly result in them trying to solicit your customers), then it depends on what your current privacy policy statement states. If you currently say you do not share info, you would need to disclose a new privacy policy to all customers with 30-days notice and provide an opt-out. If your statement currently does state that you have the right to share info, and you currently porivude an opt-out method, then you don't need to do anything differently.

Either way, if your mortgage customers are new to your bank, they need to get a copy of your privacy policy statement at closing.

Thank you for your responses. They will help me as I support the officers.