I am confused about an issue and need your help. Here's the deal. A person (not a customer, but a potential one) who is filling out a credit appliaction for a personal loan, and after running the credit report we deny them. Do we need to give them a privacy disclosure before they give us their personal information, or do we have to give them a disclosure at all??
We are a small bank and do not give out any give out or sell any personal information to any third parties.

If we do, where is the Reg does it state that. Thanks.

The GLBA requires the privacy disclosure before the first transaction and annually thereafter. If there is no transaction, then logically it would follow that there would be no disclosure.

Having said that, however, our program requires us to provide it at the time of application. We find its simply easier.

And to add a different procedure to Waldensouth...we used to give it at application..whether deposit or loan. Now it's given with the closing docs...better control for us at that control point.

Thanks for your help!!