Construction Advertising

Our mortgage broker would like to post signs on home construction sites stating "construction financing by Bank of__". Is this a violation of GLB if our policy is we do not share any information?
Also, we have disclosed our policy to our commercial customers, is this same type of signage a violation for them?

Can we avoid any problem by having the customer sign a release to use the sign?

If the construction is a commercial project, no GLB problem. Ask yourself, "Who is the customer?" GLB is a consumer law.

If the construction is an individual project, I can argue both sides. Am I releasing NPPI such as name, address, etc. and the answer is no; however, in a small community, everyone knows who is building which house, but may not know who the lender is until the sign goes up. Seems to be technically ok, but probably goes against the "spirit" of the reg. Anybody else have any thoughts.

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Opinions expressed are not necessarily those of my employer.

I like to summarize Privacy this way: I can't tell anyone who my customers are." (Yes, I know that there are lots of exceptions - this is a simple summary). By putting a sign in your front yard that basically says "This customer banks with us" I believe you have violated privacy. However, with customer consent, I can share (almost) anything. So why not ask for permission to put the sign in their yard. No problem.

I would argue that since you are recording a mortgage on the property, the fact that the customer has a loan with your bank is public information.