I send a monthly (encrypted) tape to ABC Insurance Co. For some reason, which I have not been able to figure out, not all accounts are included on this file. (Those who have opted-out are not included).

When a customer calls into our bank the CSR transfers the caller to ABC for cross selling. If the product is accepted, ABC Insurance gets either the account number or name/address from the customer and cross references it on the solicitation file. If ABC Insurance cannot find the account on the file, they call us to verify it is an active account and in the past, we provided them the customers account number. I have instructed Customer Service not to give ABC Insurance the account number. So, here’s the problem: ABC cannot send the product info to us through our interface because they do not have the account number.

In these instances where the customer has opted to be transferred to ABC and the customer has provided account info to them by either their account number or name/address, is it ok for us to provide account numbers back to ABC? We are the one initiating the transfer from the customers account, remitting a portion to ABC Insurance.

We can take an encrypted account number and locate the actual account number but we cannot do the reverse.

You may want to refer to this interpretive letter and see how it applies to your situation:

Limits on Disclosing Account Numbers