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#69878 - 03/26/03 05:14 PM Confidentiality Agreements and Bank Directors
Anonymous
Unregistered

To comply with the Gramm-Leach-Bliley Act (GLBA) employees and service providers of my bank have signed confidentiality agreements. Should we have our bank directors execute confidentiality agreements also? And if so, does anyone have a sample document for directors that they wouldn't mind sharing? Thanks for your responses!

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General Discussion
#69879 - 03/26/03 07:51 PM Re: Confidentiality Agreements and Bank Directors
gpawlak Offline
New Poster
gpawlak
Joined: Feb 2003
Posts: 9
Absolutely, every member of your Board of Directors should execute a Confidentiality/Privacy Agreement. Above all, the Directors have a fiduciary responsibility to the shareholders/owners of the bank that requires them to have the highest levels of access to the strategic and confidential information assets of the bank, among other things. Formally securing their confidentiality through a signed legal document may provide the necessary impetus to keep a Director from discussing Bank strategy or specific non-performing assets at their next cocktail party or Rotary meeting.

We normally advise our bank clients to use the general Confidentiality/Privacy Agreement that is signed by employees / management (depending on content). In any case your legal counsel should review this prior to introducing it to your Board.

If you have any questions, please contact me at gpawlak@e-tronics.com

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#69880 - 04/08/03 07:02 PM Re: Confidentiality Agreements and Bank Directors
c.a.r Offline
Gold Star
c.a.r
Joined: Oct 2002
Posts: 377
Texas, USA
Does anyone have a GLBA 501(B) policy they could share? I have searched and am a little lost.
Thanks.
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#69881 - 04/09/03 03:05 PM Re: Confidentiality Agreements and Bank Directors
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
We have language included in our codes of conduct that all officers, employees, board members and trustees sign annually. That has been suffucient.

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#69882 - 04/09/03 05:22 PM Re: Confidentiality Agreements and Bank Directors
yy2say Offline
Gold Star
yy2say
Joined: Apr 2002
Posts: 279
PA
Quote:

We have language included in our codes of conduct that all officers, employees, board members and trustees sign annually. That has been suffucient.




We do the same. The FDIC looked at this at their last examination and thought it sufficient. At least this was not cited on any examination reports.
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