I need a refresher. Some folks in the bank are insisting that annual privacy notices can be mailed at the household level even if a joint account owner lives at another address. If memory serves, according to Reg P., the privacy notices cannot be provided at the household level (rather than the individual customer level) unless the only account relationships are joint accounts and all joint owners reside in the same household. In the event all accounts are held jointly by members of the same household, the rule does allow an institution to provide one annual notice in conjunction with a joint account. If individual members of the household maintain single accounts or reside at separate addresses, a separate notice regarding those accounts must be sent to the customers. Am I correct, or have I forgotten all my Reg P training?
Leslie

I believe you are correct.

From the December 2001 Joint Q & A

D. Providing notices to joint account holders
D.1. Q. I have two depositors who hold one account jointly. The depositors share the same address. When notice is required, may I mail just one privacy notice?
A. Yes, you may mail one notice to two or more joint account
holders at the same address. § 216.9(g).

D.2. Q. What if those same account holders have different addresses?
A. You still may mail one notice to all accountholders jointly at one account holder’s address. § 216.9(g).

And remember that if you mail it to one person, if they opt out it applies to the others on the account.