Privacy Notice and Loan Origination

Posted By: SunnyFL, CRCM

Privacy Notice and Loan Origination - 11/20/13 03:57 PM

We (community bank) are going to begin originating mortgage loans for another financial institution. We will be prequalifying the consumer, collecting the necessary application information and then sending it on to the other lender for approval, closing, and servicing. This loan will not be on our books and this will not be our "customer". Is a privacy notice necessary? If yes, and we ordinarily do not share and therefore, do not provide an opt-out, would that change the notice to a "Yes" in the "marketing purposes" section, and "yes" with an opt-out provision in the "limit the sharing" section?