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#1242 - 04/06/01 09:11 PM What companies are subject to Reg P
Anonymous
Unregistered

We have an affiliate that offers insurance and mutual funds. They don't think they need to have a privacy notice. They checked with other agencies in the state who aren't doing them either. They feel the notice should come from the mutual fund company. The agencies are only brokers, but they have all the customer info. I think they are covered and should have a notice. I would like to know what others think about this.

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#1243 - 04/09/01 08:43 PM Re: What companies are subject to Reg P
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
The regulation has definitions of what is and what is not a financial institution covered by the rules. The regulations state " An investment advisory company and a credit counseling service are each financial institutions because providing financial and investment advisory services are financial activities referenced in section 4(k)(4)(C) of the Bank Holding Company Act."

I'm not sure if this accurately describes your situation as you said the affiliates offer mutual funds and insurance and later that they act as brokers.

I would certainly contact legal counsel if you are not sure as the mandatory compliance date is drawing near.

Dolly Nugent
Vice President
Compliance & CRA Officer
Citizens Business Bank

_________________________
Dolly Nugent
CRCM
Opinions expressed are my own.

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