Privacy Disclosures

Are initial and annual privacy diclosures given to customers of the trust department?

Yes, if they are consumers

Whether you have to provide them a privacy notice depends. If you hold a custodial IRA, then the privacy notice applies. Simply being a trust customer does not make them a consumer.

From the regs:


An individual is not a bank's consumer solely because he or she has designated the bank as trustee for a trust.


(vii)
An individual is not a bank's consumer solely because he or she is a beneficiary of a trust for which the bank is a trustee.

Quote:

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Simply being a trust customer does not make them a consumer.

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Exactly. That's why I put the word "if" in bold.