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In Response To:
Thread Starter: fmissle
Title: Re: Negative Information

Originally Posted By: Dan Persfull
Actually is says it must be given to customers as defined by section 509 Public Law 106--102.

From the FAQ to to GLBA:

http://www.ftc.gov/privacy/glbact/glb-faq.htm

Q&A B. 1.

. . . A customer is a type of consumer, namely, an individual who has an ongoing relationship with you under which you provide a financial product or service. . . .

Therefore if you will report negative information on the individual (customer) then yes you must provide the notice.


(not the original poster, but)... looking further, I see this
Note that neither a business nor an individual who obtains a financial product or service for business purposes is a consumer or a customer under the Privacy Rule.

So if the loan was business purpose, even if the guarantor is an individual, do you still have to give them the notice? That makes me think no.