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#63165 - 02/24/03 05:01 PM Privacy & Statements
Wigsout Offline
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Wigsout
Joined: Oct 2002
Posts: 40
Tulsa, OK
My memory fails me, can the privacy notice be preprinted on the bank of statements like Reg. E?
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General Discussion
#63166 - 02/24/03 05:06 PM Re: Privacy & Statements
Andy_Z Offline
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Andy_Z
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Posts: 27,748
On the Net
The notice has to be clear and conspicuous. If you can achieve that you'd be OK, but I'd recommend drawing attention on the front, to the back. This could be a challenge.
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My opinions are not necessarily my employers.
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#63167 - 02/24/03 05:14 PM Re: Privacy & Statements
Anonymous
Unregistered

I assume you are referring to the annual notice. Andy is right, safe to at least make mention of it on the front if possible. What I do as a cost savings measure is I use my quarterly newsletter, which I send to all my DDA accounts in their statements anyway, and I give up the back page for the Privacy Policy Statement. I then include a small section on the front that has a short blurb from our President advising them about the statement on the back. Also as a cost saver, the annual disclosure I send to all others (s/a's, loan customers with no dda, etc.) get a one page letter with the purpose of the mailing on the front, and the policy statement on the back.

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#63168 - 02/24/03 11:41 PM Re: Privacy & Statements
Anonymous
Unregistered

Everything I've read recommends a separate piece. Our members regularly throw out the newsletters without reading them. I use the same privacy notice that we provide to new accounts, and mail it out with the quarterly statements.

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#63169 - 02/25/03 01:08 AM Re: Privacy & Statements
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
While I agree that a separate piece is more clear and conspicuous, that doesn't mean it will be read.

One thing I will add, if you allow an opt-out, make sure they can opt-out without returning a piece of their statement with other data they have to be able to keep. The initial draft of our notice would have required the customer to complete and detach the last page of their notice. Since that also meant they'd lose the last page of text, I felt that took away their ability to retain the notice. I had mixed replies when I asked about this, but will hold that it is inappropriate. It is the same premise as requiring an ATM customer to surrender their receipt to enter a drawing.
_________________________
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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#63170 - 02/25/03 02:48 PM Re: Privacy & Statements
Anonymous
Unregistered

We also send the privacy statement that is given out at time of account opening as our annual mailing in quarterly statements. For our Safe Deposit Boxes we run labels and do a mailing.

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#63171 - 02/25/03 03:03 PM Re: Privacy & Statements
1111 Offline
Platinum Poster
1111
Joined: Jan 2003
Posts: 580
Quote:

What I do as a cost savings measure is I use my quarterly newsletter, which I send to all my DDA accounts in their statements anyway, and I give up the back page for the Privacy Policy Statement.




What about those customers that do not have a DDA account? Notice needs to be provided to all customers, including those with just a savings or loan account. Statement stuffer is the best with a notation on the statement that refers to the stuffer.

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#63172 - 02/25/03 03:06 PM Re: Privacy & Statements
Anonymous
Unregistered

Ipso - did you get bored with my post after the first sentence? I do send to the others, just in a separate piece as I mentioned.

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