Privacy Issue?

A County Auditor, in one of our multiple counties where we do business, asked that we send them a list of loan numbers for those mortgage loans where we escrow and remit property tax payments to the county. I think a loan number is non-public personal information. Previously, the parcel number was used to apply payments. Our Privacy Notice states that we do not share with non-affiliates. Some banks are electing to provide loan numbers but I see that other banks are not providing the loan number. Does anyone agree we should not provide or disagree and feel we should provide? Any helpful insight would be appreciated.

how do you provide the information when you remit payment to the county for the escrow? Whatever info is provided in that should be sufficient for you to provide now.

You are right that the loan numbers are nonpublic personal information. The real question is whether this type of sharing falls within the privacy exceptions.

Attached is a link to an interpretive letter from the regulators concerning sharing loan numbers for a slightly different purpose, on recorded documents. It indicates that "there is an exception for disclosures that are "necessary to effect, administer, or enforce a transaction" that applies to, among other things, a disclosure that is "required, or is a usual, appropriate, or acceptable method to carry out the transaction or the product or service business of which the transaction is a part, and record or service or maintain the consumer's account in the ordinary course of providing the financial service or financial product...."

Interpretive letter 917

Why would they need the loan number?

It sounds as though they will be using them to apply the payments. Under the language for the exceptions, it does not have to be information that is absolutely required, it only has to be a "usual, appropriate, or acceptable method" of handling the account.

Huh? The bank's loan number would have nothing to do with their account number to apply a payment. That just doesn't make sense.

Thank you for your replies and the link. Currently they use the parcel number but have for some reason changed the manner that they are sending the tax bill to us so that it will contain the loan number not the parcel number. I agree it does not make sense and I am not eager to share the loan number.