This is a basic privacy question, that I have already answered in my institution, but now I am being questioned and I am totally confused.
Here goes ... must we send a privacy notices to people whom are sold non investment products through an agent at our bank?
On one hand it seems as though they are applying for a service which requires us to share their information, therefore exempting the requirement of a privacy notice.
But on the other hand they are receiving "investment advice" which would make them classified as a customer.
I thought I was clear on this, but I have myself totally confused

Our "dual employees" wear two hats. When they sell a NDIP, they are not wearing the bank hat, and the bank does not sell the NDIP. The NDIP provider must handle the privacy notices for their customers.

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.