GLBA-Privacy

I have a question maybe you can answer, we are a non-sharing bank, however our marketing department wants to insert folders from one of our customers about there service in our statements. Does this violate the GLBA.?

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GLB will address your sharing of a customers information with others, not the stuffing of an ad in the customer's statement. You should have no privacy worries there so long as you don't tell the vendor who in particular these went to.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

thanks andy, however, couldn't this insert be concieved as yet another vendors way of solicition thru the statement. Is this an unsolicited solicitation?

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I agree with Andy....GBL will look at the info that YOU share about YOUR customers with others.

By stuffing a vendor advertisement into an envelope, you are not giving out customer information.

It may be an unsolicited solicitation, but it is not what G-L-B prohibits. The law prohibits violating the customer's privacy by sharing information with the vendor. In this situation, you have put the shoe on the other foot by sharing information about the marketer's product with your customer. You are not releasing the customer's name or information about them.